OFFICIAL LEGAL TEXT · PRACTICAL CONTEXT
Below is the official legal text reproduced for convenient reference inside CryptoLicense.ge. Our VASP analysis identifies how the document affects registration, operations or compliance; it does not replace or alter the legislation.
Source statusCurrent consolidated official English text reproduced from Matsne
What this document covers
The Tax Code is the primary statutory framework for Georgian taxation. Crypto and VASP tax outcomes cannot be determined from a single slogan: corporate profit tax, VAT, employment, withholding, source and cross-border rules depend on the taxpayer and the activity actually performed.
Why it matters for VASP work
A VASP registration plan should include the tax operating model from the beginning. Customer location, group services, payroll, provider arrangements, treasury and income character can change the result, and the 2019 public cryptoasset decision should be read within the wider Tax Code rather than as a blanket “tax-free crypto company” rule.
Official text
English — current consolidated official text LAW OF GEORGIA
TAX CODE OF GEORGIA
SECTION I
GENERAL PROVISIONS
Chapter I – Georgian Tax System
Article 1 – Scope of regulation of the Tax Code of Georgia
This Code defines, in accordance with the Constitution of Georgia, the general principles of formation and operation of the tax
system of Georgia, the legal status of tax payers and competent authorities, the types of tax offences, the liability for violating the
tax legislation of Georgia, the procedure and conditions for appealing wrongful acts of competent authorities and their officials,
the procedure for settling tax disputes, and governs the legal relations connected with the fulfilment of tax liabilities.
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2 – Tax legislation of Georgia
1. The tax legislation of Georgia comprises the Constitution of Georgia, international treaties and agreements, this Code and
subordinate normative acts adopted in compliance with them.
2. The tax legislation of Georgia in effect at the moment when tax liability arises shall be used for taxation.
3. The Government of Georgia or the Minister of Finance of Georgia shall adopt/issue subordinate normative acts for enforcing
this Code.
4. (Deleted – 26.12.2013, No 1886).
5. To enforce the tax legislation of Georgia, the head of the Legal Entity under Public Law (LEPL) within the Ministry of Finance
of Georgia – the Revenue Service (‘the Revenue Service’) shall issue orders, internal instructions and guidelines on application of
the tax legislation of Georgia by tax authorities.
6. When regulating tax matters, the terms and concepts of the legislation of Georgia used in this Code shall have the same
meanings as they have in the respective legislation, unless otherwise provided for by this Code.
7. Any international tax-related treaty that has been ratified by the Parliament of Georgia and that has entered into force shall
prevail over this Code.
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 3 – Setting timeframes
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1. The timeframes set by this Code shall be determined by a specific calendar date or a period calculated in years, months or days
and/or by reference to the appropriate circumstance.
2. The timeframe set by this Code shall commence on the day following the performance of the relevant action. A day may be a
business day or a calendar day. If not specified, a day shall be a calendar day. Unless otherwise provided for by the tax legislation
of Georgia, a business day shall coincide with a calendar day, except for a Saturday, Sunday and the holidays determined by the
Organic Law of Georgia on the Labour Code of Georgia.
3. The timeframe calculated in years shall end in the respective month and day of the last year of the timeframe.
4. The time frame calculated in months shall end on the respective day of the last month of the timeframe.
5. An action for which a timeframe is set may be performed by the end of the last business day of the timeframe, and if the action
is performed through a bank transfer, mail and/or electronic means, the action may be performed by 24:00 of the last day of the
timeframe.
6. If the last day of the performance of the action coincides with a non-business day, the timeframe for the action shall be
extended to the end of the next business day, and where the action is performed through a bank transfer, mail and/or electronic
means, the action may be performed by 24:00 of the next business day.
7. A calendar year shall be the period from 1 January through 31 December of any year; for a newly registered taxpayer a calendar
year shall be the period from the registration date through 31 December of the same year, unless otherwise provided for by this
Code.
8. A year (other than a calendar year) is a period consisting of any consecutive 12 calendar months.
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 4 – Period of limitation
1. The period of limitation for assessing taxes to a taxpayer and for submitting a notice of tax liability to the taxpayer shall be three
years, unless otherwise provided for by this Code.
2. The period referred to in the first paragraph of this article shall commence from the end of the calendar year in which the
respective tax liability arose.
3. The period of limitation for imposing sanctions (other than a penalty) under this Code on a taxpayer and for submitting a
relevant tax notice to a taxpayer shall be three years, unless otherwise provided for by this Code.
4. The period referred to in the third paragraph of this article shall commence:
a) from the end of the calendar year in which the tax offence was committed, except as provided for by subparagraph (b) of this
paragraph;
b) from the end of the calendar year in which the tax liability arose, if the calculation of the amount of the sanction provided for
in this Code is related to the amount of the tax liability.
5. The period of limitation for a tax audit of taxpayers shall be three years, unless otherwise provided for by this Code.
6. The period referred to in the fifth paragraph of this article shall commence from the end of the calendar year in which the audit
takes place.
7. The period of limitation referred to in the first, third and fifth paragraphs of this article shall be extended for one year if less
than a year remains before the expiry of the period and the taxpayer has filed with a tax authority a taxpayer’s claim or a tax
return (including an adjusted tax return) for the relevant period.
8. The period of limitation for a taxpayer to file a taxpayer claim with a tax authority shall be three years, which will be calculated
from the end of a calendar year in which the right to refund for the sum of any overpaid tax and/or sanction (including customs
sanction) arose.
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9. The period of limitation for serving an individual administrative-legal act on tax enforcement measures as provided for in this
Code to a taxpayer, registration authority or banking institution shall be three years, commencing from the end of the calendar
year in which the tax arrears were incurred.
10. In the cases provided for in the ninth paragraph of this article, the period of limitation for serving an individual administrative-
legal act shall be suspended:
a) from the entry into force of a ruling on recognising as admissible a person’s application for insolvency and on opening the
rehabilitation or bankruptcy regime till the end of the regime concerned, and during the validity period of the rehabilitation plan;
b) (Deleted – 6.3.2024, No 4056);
c) during a tax dispute;
d) during the validity period of an agreement for deferral of enforced payment of tax arrears;
e) during the validity period of a tax agreement act;
f) where so provided for by Article 238(7)(a) of this Code.
11. The periods of limitation provided for by this article shall not apply:
a) during the enforcement period of a judgment of a court/dispute resolution body by a tax authority;
b) in relation to the submission of a motion for recognising a person as a straw man for a taxpayer by a tax authority to the court
on the basis of Article 246 of this Code, and to the application of measures of securing the enforcement of payment of tax arrears,
as provided for by this Code, against the straw man for the taxpayer.
12. When the loss is carried forward for 3 years or more, the period of limitation under paragraphs 1, 3 and 5 of this article in
relation to the tax liabilities of a calendar year the loss was incurred, the amount of which is affected by such loss shall be extended
and it shall exceed the loss carry forward period by one year. In such a case, the period of limitation shall be counted from the end
of the calendar year the loss was incurred.
13. The period of limitation under paragraphs 3 and 5 of this article for submitting a tax notice to a tax payer shall not be
considered laches if a tax authority has posted the tax notice on the tax payer’s authorised user web page before expiry of the
period of limitation.
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3581 of 1 May 2013 – website, 15.5.2015
Law of Georgia No 3583 of 1 May 2013 – website, 15.5.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4056 of 6 March 2024 – website, 14.3.2024
Article 5 – Principles of the tax legislation of Georgia
1. A person shall pay national and local taxes established under this Code.
2. No tax obligation introduced in violation of this Code or not provided for in this Code may be imposed on a person. No person
may be forced to pay taxes earlier than required by this Code.
3. A municipality representative body may introduce only the local tax provided for by this Code.
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 6 – Concept and types of taxes
1. A tax is a mandatory, unconditional monetary payment to the budget made by a taxpayer in accordance with this Code, based
on the necessary, non-equivalent and gratuitous character of the payment.
2. Taxes shall be national and local.
3. National taxes shall be the taxes provided for under this Code, the payment of which is mandatory across the whole territory of
Georgia.
4. A local tax shall be a tax imposed by this Code and introduced by a normative act of the municipality representative body –
Sakrebulo (within marginal rates), the payment of which is mandatory within the administrative boundaries of the municipality
concerned.
5. National taxes shall be:
a) income tax;
b) profit tax;
c) value added tax (VAT);
d) excise tax;
e) import duty;
6. A property tax shall be a local tax.
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 7 – imposing and introducing a local tax; changing its payment conditions and abolishing the tax
1. A municipality representative body may introduce a local tax imposed by this Code as a flat rate tax within the administrative
boundaries of the municipality and/or according to individual branches and/or types of businesses within the administrative
boundaries of the municipality, within the marginal rates set by this Code.
2. A municipality shall forward information on introducing a local tax, changing its payment conditions or on abolishing the
introduced local tax and a copy of the relevant normative act upon publication to the Revenue Service of Georgia and to the
appropriate tax authorities.
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Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 71 – Requirements for payment accounts opened with payment service providers
1. Provisions defined by Articles 54, 71, 238(1)(c) and (e), 241(7), (8), (10) and (11), and Article 243(1), (2) and (4) of this Code for
a banking institution with respect to a bank account shall apply to a payment account of a tax payer opened with a payment
service provider registered in accordance with the Law of Georgia on Payment Systems and Payment Service if he/she has
included a legal person, or an individual entrepreneur registered in accordance with the legislation of Georgia, and another
organisational entity in the electronic money scheme, as a payer.
2. If a payment service provider provided for by paragraph 1 of this article fails to fulfil the respective obligation, liabilities defined
by Article 283 of this Code shall apply to it respectively.
3. For the purposes of paragraph 1 of this article, the tax authority shall refer to the list of payment service providers published on
the webpage of the National Bank of Georgia under Article 18(11 2) of the Law of Georgia on Payment Systems and Payment
Service.
Law of Georgia No 1808 of 9 September 2022 – website, 23.9.2022
Chapter II – Terms and Concepts Used in This Code
Article 8 – Definition of terms
1. Non-depreciable fixed asset – a fixed asset not losing its value during the process of operation.
2. Intangible asset – an identifiable non-monetary asset without physical substance used by a person for manufacturing goods,
supplying goods/rendering services, leasing it to others and/or for administrative purposes. Intangible assets include: copyright,
patent, trademark, goodwill, software, licence, leasehold, franchise, mining rights, special import and export rights and other
similar intangible assets.
3. Indirect tax – a tax (value added tax, excise tax, import duty) imposed as an addition to the price of goods supplied (imported)
and/or services rendered and that is paid by a consumer (importer) when purchasing (importing) goods and/or services at the price
increased by such tax. The obligation to pay an indirect tax to the budget is imposed upon the supplier (importer) of goods and/or
services who is referred to as a taxpayer for the purposes of this Code.
4. Non-resident – a person who is not a resident.
5. Acknowledged tax arrears – tax arrears if:
a) the basis of tax assessment is a tax return/customs declaration;
b) a person has failed to appeal a tax notice issued by a tax authority, or the decision of a dispute resolution authority, within the
timeframe set by this Code;
c) the Revenue Service and a taxpayer have signed an agreement to reduce tax arrears;
d) a court decision on the lawfulness of the tax assessment has taken effect;
e) a person, by a written/electronic application, has refused to appeal against the decision of a tax dispute resolution body;
f) a person has submitted a written application to a tax authority under the procedure determined by the Minister of Finance of
Georgia for refusing to appeal the tax notice.
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6. Biological asset – an animal or a plant.
61. Agricultural activity – activity under International Accounting Standards 41.
62. Agricultural produce – produce obtained from agricultural activity. At the same time, changing of a commodity classification
code as a result of biological transformation or harvesting product from a biological asset (detachment of produce or the cessation
of the life process of a biological asset) shall not be considered as industrial processing (changing commodity classification code) of
agricultural produce.
63. Agricultural cooperative – a legal person that has been granted the status of an agricultural cooperative under the Law of
Georgia on Agricultural Cooperatives.
7. International Accounting Standards (‘IAS’) – the standards approved by the International Accounting Standards Committee and
introduced for application under the resolution of the Commission of Accounting Standards of the Parliament of Georgia.
8. Administration of taxes – a set of forms, methods and rules employed by tax authorities when enforcing the tax legislation of
Georgia to ensure the computation, payment and declaration of taxes, as well as tax control, registration and notification of
taxpayers, and the fulfilment of tax liabilities.
9. Taxpayer identification number – a number allocated to a taxpayer under the tax legislation of Georgia.
10. Long-term contract – a contract that is not completed in the same calendar year in which the services under the contract
commence and when it contracts for the manufacture, installation, construction or delivery of services related to those activities,
except for a contract that expires within six months after the commencement of the services under the contract.
11. Shortage – shortage of inventory and/or fixed assets identified during the comparison (including by means of stock-taking) of
inventory and/or fixed assets with a taxpayer's accounting records. Shortage in connection with inventory that cannot be
physically warehoused (electric and thermal energy, gas and water) shall be the difference between the purchased (according to
proof of purchase documents) and the sold (actually released from a taxpayer) inventory, provided that the customer (payer)
and/or the person misappropriating the inventory and/or fixed assets cannot be identified. At the same time, a competent
authority may set a maximum amount of loss. In such case, the loss in excess of that amount shall be deemed as shortage. In the
case of stamping/marking of the goods in immaterial form in accordance with procedures determined by the tax legislation of
Georgia, the loss identified by the manufacturer in the process of manufacturing shall not be deemed as shortage.
12. Dividend – any income (including interest from preference shares) earned by a shareholder/interest-holder from shares or
rights (interests) as a result of a distribution of profits made by a legal person to its shareholders/interest-holders in proportion, or
not in proportion, to their shares/rights in the capital. Where a repo agreement, securities lending and financial collateral are
involved, a compensatory amount received by a seller/lender from a buyer/lendee, which is the dividend actually received from
the securities during the validity period of such transaction. In addition, dividends shall not include:
a) payments/disbursements made in cash or in kind at the time of liquidation of a legal person or at the time of buying out
shares/interest, which does not exceed the amount of the contribution made by a shareholder/partner to the capital (outstanding
and additional paid-in capital);
b) payment made to a shareholder/interest-holder of a legal person by transferring the shares/interest of the same legal person into
ownership, except for transferring by a resident legal person the equity securities issued through a public offering in Georgia and
allowed for trading on an organised market recognised by the National Bank of Georgia.
13. (Deleted – 23.12.2017, No 1935).
14. Compensation – property and/or benefit received by a person in compensation for the supply of goods, rendering of services,
costs, loss or shortage.
15. Tangible asset – any asset that is not an intangible asset.
16. Family – a person, his/her spouse, minor children and step-children, as well as parents, children and step-children, sisters,
brothers, grandmothers, grandfathers, grandchildren permanently living with the person while maintaining a common household.
For the purposes of this Code, a taxpayer shall unconditionally define the circle of persons (from the above ones) who live with
him/her permanently and maintain a common household.
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17. Partner – a partner, a shareholder, a limited partner, a general partner, a member of a cooperative under the Law of Georgia on
Entrepreneurs.
18. Person – a natural or legal person under the Civil Code of Georgia, an enterprise, or an organisation under the Tax Code of
Georgia.
19. Interest – any pre-declared (established) income (including that received as a discount) from any debt claim related to cash
investments or debt obligations (whether backed by mortgage or securitised in any other way). At the same time, for the purposes
of this paragraph:
a) debt obligations shall not include debt obligations arising from the supply of goods and/or rendering of services, or obligations
arising from guarantee and/or surety and/or other similar transactions;
b) the following shall be regarded as interest:
b.a) (Deleted – 28.6.2023, No 3350);
b.b) an amount payable in respect of a credit (loan), deposit, bond;
b.c) income from government securities and bonds, including the premiums and profits accrued on them;
b.d) part of the sum of a difference between the securities supply price and purchase price, in the amount of an unpaid interest
accrued on the securities before the moment of their supply;
b.e) within a repo agreement, a difference between the loan securities selling price and a pre-agreed redemption price of this or
other equivalent loan securities;
b.c) within a repo agreement, securities lending or financial collateral, a sum of payment received by a seller/lender from a
buyer/lendee, which is an interest accrued on the securities within the validity period of this transaction and actually received by
the buyer;
c) a penalty for delayed payment or delayed delivery shall not be regarded as interest.
20. Resident – a resident natural or legal person (a Georgian enterprise or a Georgian organisation).
21. Royalty:
a) a fee for the right to use subsoil in the course of extracting minerals and processing anthropogenic formations;
b) income received for the right to use copyrights, software, patents, drawings, models, trademarks or other intellectual property
or for transferring the right to another person;
c) income received for the right to use industrial, trade or research equipment or for transferring the right to another person;
d) income received for the use of know-how;
e) income received for the right to use cinematograph films, video films, audio records or other recording devices or for
transferring the right to another person;
f) income received for the right to use a secret formula or process, as well as information containing industrial, commercial or
scientific experience or for transferring the right to another person;
g) income received for providing technical assistance in connection with the rights provided for in this paragraph or from the
waiver of these rights.
22. Accounting documents – source documents (including tax source documents), ledgers and other documents on the basis of
which objects of taxation and objects related to taxation are determined and tax liabilities are established.
23. Tax arrears – the difference between the amount of taxes and/or sanctions (including a customs sanction) not paid within the
set time limit by a taxpayer and the overpaid amount of taxes and/or sanctions (including a customs sanction).
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24. Foreign Economic Activity Commodity Nomenclature – a system of commodity classification codes, adopted under the
International Convention on Harmonization of Commodity Description and Coding System.
25. International carriage – any carriage of passengers or goods (including mail) by a motor vehicle, railway vehicle, marine vessel,
internal land water vehicle or an aircraft between two points located in different states, one of which is Georgia. In addition, an
international carriage shall not include:
a) carriage performed only between points located outside the borders of Georgia or only between points within the borders of
Georgia;
b) transportation of goods through pipelines or power transmission lines.
26. additional paid-in capital – the difference between the amount received or receivable by an enterprise from an initial public
offering of shares and the total nominal value of those shares, as well as the excess of the value of non-cash contributions made at
the moment of founding of an entrepreneurial company over the agreed upon amount.
27. Profit received from a person engaged in gambling business – income that is a positive difference between the amount received
by a natural person (player) from one ticket, counter, coin and/or other means of gambling and games of chance and the amount of
the stake and/or the cost of the item.
28. Inventory – raw materials, materials, semi-finished goods, spare parts, containers and finished products (goods) used by a
person in the ordinary course of business under International Accounting Standards.
29. Bad debt – claim or part of it recognised by a taxpayer as a result of the sale of goods and/or services or as a result of the
prepayment made in respect of such sale, the due date of which has expired and which has not been paid by the end of the current
tax year, and at the same time one of the following documents are available:
a) a legally effective court/arbitration decision on refusal to satisfy the claim;
b) a notice issued by an enforcement agency regarding the non-receipt or partial receipt by a creditor of the amount payable to
him/her as a result of the enforcement of a writ of execution;
c) a legally effective court ruling on recognising as admissible an application for insolvency and on opening the rehabilitation or
bankruptcy regime in relation to a person in question, unless the judge has recognised the creditor’s claim;
d) a notice of revocation of registration issued by the Register of Entrepreneurial and Non-entrepreneurial (Non-commercial)
Legal Entities or a death certificate.
30. Property – assets of every kind both tangible and intangible, which can be purchased, possessed, managed and used by persons
without limitation.
31. Fixed asset – a tangible asset that a person uses for manufacturing goods, supplying goods/rendering services, for renting out
(including leasing out) and/or for administrative purposes, the useful life of which is longer than a year.
32. Fixed asset repair costs – costs, which increase the initial (original, standard) efficiency of fixed assets (including, modification
(reconstruction) of the elements of buildings and structures to prolong their useful life and increase their efficiency; improvement
of the parts of equipment and machinery to increase their efficiency, and introduction of new production processes), other than
current maintenance costs, which are incurred in relation to restoring and maintaining the initial efficiency of the fixed assets.
33. Entertainment expenses – expenses incurred by a person within the scope of economic activity, which include:
a) expenses (for juices, mineral waters, soft drinks, tea, coffee, breakfast, lunch, dinner, banquet) related to events (presentations,
receptions) arranged on behalf of a person;
b) expenses for excursions and cultural and entertainment events;
c) souvenir costs;
d) guest service costs, including:
d.a) consular service (visa processing and extension) costs;
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d.b) costs of meeting and departure at an airport (VIP Hall service);
d.c) transportation costs;
d.d) hotel service (reservation, accommodation) costs;
d.e) costs related to receptions and parties (juices, mineral waters, soft drinks, tea, coffee, breakfast, lunch, dinner, and banquets).
34. Net assets – difference between a person's assets and liabilities.
35. A virtual zone person – a legal person engaged in IT activities and holding an appropriate status.
36. Information Technologies (IT) – studying, supporting, developing, designing, producing and introducing computer information
systems, as a result of which software products are obtained.
37. Tourist zone entrepreneur – a person (entrepreneurial entity) who builds a hotel and ensures its operation under the Law of
Georgia on Promoting the Development of Free Tourist Zones.
371. Agro tourism operator – a person granted the status of agro tourism operator in accordance with an ordinance of the
Government of Georgia.
372. Wine tourism operator – a person granted the status of wine tourism operator in accordance with an ordinance of the
Government of Georgia.
38. Leasing – leasing within the meaning of the Civil Code of Georgia, if the leased item is a depreciable asset.
39. Leasing Company – an enterprise whose income from leased out property during a calendar year is at least 70% of its income.
40. Donation – goods/services, including funds received by an organisation as gifts.
41. High-mountain settlement – a high-altitude settlement as defined by the Law of Georgia on the Development of High-
mountain Areas.
42. High-mountain settlement enterprise – an enterprise/individual entrepreneur that carries on business in a high-mountain
settlement and enjoys the status of a high-mountain settlement enterprise under the Law of Georgia on the Development of High-
mountain Areas.
43. Net profit – any profit that can be distributed as dividend, under the procedure established by the legislation of Georgia.
44. Income – any income according to the international accounting standards.
45. Loan provider – an entity providing loans under the Organic Law of Georgia on the National Bank of Georgia.
46. Taxation year – a calendar year.
47. Import – placement of goods under the Release for free circulation procedure in accordance with the Customs Code of Georgia.
48. Temporary admission – placement of goods under the temporary admission procedure in accordance with the Customs Code of
Georgia.
49. Customs sanction – a measure of liability for a customs offence provided for by the Customs Code of Georgia.
50. Export – placement of goods under the export procedure in accordance with the Customs Code of Georgia;
51. Repo agreement, reverse repo agreement – a transaction defined by the Law of Georgia on Financial Collateral, Mutual
Deduction and Derivatives, if the transaction has been concluded in compliance with market principles, securities are redeemed
during 12 months from their sale and this transaction provides for payment by the buyer to the lender of an interest accrued on
the securities and actually received during the validity period of the agreement, a dividend (voucher) or any other distribution,
which means the equivalent payment thereof.
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52. Securities lending – a transaction defined by the Law of Georgia on Financial Collateral, Mutual Deduction and Derivatives, if
the transaction has been concluded in compliance with market principles, securities are returned during 12 months from their
primary supply and this transaction provides for payment by the lendee to the lender of an interest accrued on the securities and
actually received during the validity period of the agreement, a dividend (voucher) or any other distribution, which means the
equivalent payment thereof.
53. Financial collateral – a transaction defined by the Law of Georgia on Financial Collateral, Mutual Deduction and Derivatives.
54. Derivative – a transaction defined by the Law of Georgia on Financial Collateral, Mutual Deduction and Derivatives.
55. Banking institution – a commercial bank defined by the Law of Georgia on Commercial Bank Activities, or a microbank
provided or by the Law of Georgia on Microbank Activities.
56. Entity in the process of winding up (wound up company) – an entity (except for a branch established by a natural person, who
is an entrepreneur natural person) against which the commencement of the process of winding up has been registered, under the
Law of Georgia on Entrepreneurs (the liquidation process of which has been in progress).
Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5452 of 9 December 2011 – website, 22.12.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 817 of 12 July 2013 – website, 5.8.2013
Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 4037 of 16 July 2015 – website, 28.7.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
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Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3317 of 28 June 2023 – website, 18.7.2023
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3922 of 13 December 2023 – website, 27.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 9 – Economic activity
1. Any activity shall be considered economic activity if it is performed to gain income or compensation, irrespective of the result
of the activity, unless otherwise provided for by this Code.
2. The following shall not be economic activity:
a) activity of public authorities, national regulatory and municipality bodies, which is directly related to the performance of the
functions assigned to them under the legislation of Georgia, other than the delivery of paid services under a contract;
b) charitable activity;
c) religious activity;
d) hired work;
e) placement of funds by natural persons into deposit accounts in banking institutions and other credit institutions;
f) types of activities and/or operations and/or a set of operations defined by order of the Minister of Finance of Georgia, in
agreement with the Financial-Budget Committee of the Parliament of Georgia.
3. Free delivery of goods/services shall be deemed as economic activity if performed by:
a) an enterprise;
b) an entrepreneur natural person within the framework of the activity provided for by Article 2(2) and Article 3(1 and 2) of the
Law of Georgia on Entrepreneurs.
Law of Georgia No 1588 of 20 November 2013 – website, 3.12.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
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Article 10 – Charitable activity
1. Charitable activity shall include:
a) voluntary and gratuitous assistance rendered directly or through a third person, to persons who need such assistance, including:
a.a) to natural persons in need of social protection, natural persons in need of medical assistance, to low-income natural persons
(including, persons with disabilities, the elderly, orphan children, those that have lost breadwinners, persons with international
protection and internally displaced persons from the occupied territories – ill persons, multi-child families and their members,
people affected by wars, armed conflicts, accidents, natural disasters, catastrophes, epidemics and/or epizooties.
a.b) to organisations providing services to children, the elderly and persons with disabilities, including fostering institutions,
residential schools, boarding schools, early and preschool fostering and educational institutions and other children facilities, soup
kitchens for serving the elderly, medical institutions, and rehabilitation centres;
a.c) to charitable organisations;
a.d) to religious organisations;
a.e) to specially gifted natural persons – to develop their talent;
a.f) to penitentiary institutions – to improve care and medical services of persons placed in these institutions;
a.g) to persons engaged in the activity provided for in paragraph 1(b) of this article;
b) the performance of socially beneficial activities by organisations in the following spheres: protection of human rights,
protection of environment, development of democracy and civil society; culture, education, science, healthcare, social protection,
physical education, amateur sports, and art.
2. Charity shall not include activities referred to in the first paragraph of this article if the activities are:
a) performed by the state and municipality bodies;
b) performed to support an enterprise, a political party or any other person participating in elections;
c) performed by a natural person for his/her own relatives or by a legal person for the heads of its management bodies and their
relatives;
d) regarded as sponsorship by the Law of Georgia on Advertising.
Law of Georgia No 5371 of 6 December 2011 – website, 20.12.2011
Law of Georgia No 3530 of 1 May 2015 – website, 18.5.2015
Law of Georgia No 5372 of 8 June 2016 – website, 24.6.2016
Law of Georgia No 57 of 1 December 2016 – website, 15.12.2016
Law of Georgia No 499 of 23 March 2017 – website, 27.3.2017
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025
Article 11 – Religious activity
1. Religious activity shall be the activity of duly registered religious organisations (associations) aimed at disseminating religion
and belief, including by means of:
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a) organising and holding religious rites, ceremonies, prayers and other religious acts;
b) giving opportunity to believers to have or use buildings of worship or ceremonial structures to satisfy religious needs, both
jointly and individually;
c) organising reception and departure of religious delegations, pilgrims, representatives of different confessions, organising
national and international religious conferences, congresses and seminars, providing hotel (or other) accommodation, transport,
food and cultural services to the participants during such events;
d) maintaining monasteries, minsters, theological educational institutions, teaching students and listeners of those theological
educational institutions, maintaining charitable organisations (hospitals, shelters, specialised facilities for the elderly and persons
with disabilities), and other similar statutory activities under canonical rules.
2. The activity of the enterprises of those religious organisations (associations) that publish religious (religious service) literature or
produce objects of religious significance shall be treated as religious activity; the activity of these organisations (associations) or of
their enterprises that is related to the sale (dissemination) of religious (religious service) literature or objects of religious
significance; as well as the use of funds derived from such activity to perform religious activity.
Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025
Article 12 – Hired work
1. Hired work shall mean:
a) performance of obligations by a natural person within the scope of the relations governed by the labour legislation of Georgia
and/or of a foreign country;
b) performance of an obligation by a natural person, which is related to his/her service in the defence forces, law enforcement
bodies of Georgia and other equivalent bodies;
c) holding the position the head (director) of an enterprise (organisation) by a natural person or carrying out the duties of the head
(director) of an enterprise or an organisation;
2. For the purposes of this Code, a hired natural person shall be referred to as an employee, a person paying compensation for the
work performed by such natural person shall be referred to as an employer and such compensation shall be referred to as a salary.
3. The employer shall enter information about the hired persons provided for in this article into the register of hired persons,
which is maintained by the Revenue Service.
4. The list of information to be entered into the register of hired persons and the procedure for entering information shall be
defined by an order of the Minister of Finance of Georgia.
Law of Georgia No 3600 of 31 October 2018 – website, 21.11.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 13 – Goods
1. Goods shall be a tangible or an intangible property, including electric and thermal energy, gas and water.
2. (Deleted – 14.7.2020, No 6817).
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
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Article 14 – Service
1. Activity that is not a supply of goods shall be regarded as service. Unless otherwise provided for by the tax legislation of Georgia,
service shall include:
a) construction and installation;
b) repair;
c) restoration;
d) development;
e) geological and exploratory activities;
f) transportation, including transportation of gas, oil, oil products, electric and thermal energy;
g) property letting, renting or leasing;
h) intermediary’s activities;
i) personnel selection;
j) transfer of the right to use patents, certificates, licenses, trademarks, service marks, intellectual property and other personal non-
property rights;
k) fulfilment of obligations – acting or refraining from action;
l) communication service, household and public utility services;
m) advertising services;
n) innovative services;
o) financial transactions and/or financial service;
p) insurance service;
q) consulting, legal, accounting, audit and marketing services;
r) data processing and information support services;
s) service for preparing goods for sale, including breaking down of a consignment, forming for shipment, sorting, packing,
repacking, bottling;
t) service for storing goods or other property;
u) security service;
v) production of goods or other property with the client's raw materials (materials);
w) cargo-handling service, including forwarding, loading, unloading and transhipment services;
x) service for seagoing ships, including port service, port vessels service;
y) service for aircraft, including air navigation services provided in Georgian airports, airspace and cosmic space;
z) other services.
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2. Production of goods with the client's raw materials (materials) shall be any production of goods, including preparation,
processing, treatment of goods or other transformation of the raw materials (materials), in the process of which the owner of both
the raw materials (materials) and of the final product is the person who supplied the raw materials (materials) and paid, in cash or
in kind, the cost of the service related to the production of goods with such raw materials (materials) (irrespective of whether in
the production of such goods the producer used its own raw materials (materials), component or other parts, the cost of which was
included in the cost of the service related to such production).
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 5503 of 22 June 2016 – website, 12.7.2016
Article 15 – Financial instruments, financial transactions, financial services
1. A financial instrument shall be an agreement (contract) that gives rise to both financial asset of one person and financial liability
of another person. It shall include: funds (cash or non-cash), loans (credits), loan obligations, promissory notes and securities,
shares in capital, shares, bonds and such derivatives as: options, futures, forwards, swaps, etc. Financial instruments shall also
include any agreement between two entities (contracting parties) that is denominated in money and permitted by the legislation
of Georgia. At the same time, if goods and/or services, except for financial transactions and supply of services, are supplied under
that agreement or at any stage of the operation of that agreement, between the holders of that financial instrument and/or
for/from third persons, the agreement shall no longer be considered a financial instrument after such supply.
2. The following shall be considered financial service/transaction:
a) opening, managing, closing any type of account (including current, settlement, deposit, brokerage, etc. accounts), as well as
using any payment instrument, including processing/executing transfer orders in the payment system, as well as carrying out
clearing and cash or non-cash settlements (including collection services);
b) circulation of financial instruments and cash or non-cash transactions relating to the circulation, as well as the use of any
payment instrument;
c) obtaining/issuing/transferring, syndicating, structuring, managing and using a credit (loan), including actions taken to secure a
credit (loan) (pledging property/assets, re-selling the credit risk to a third person in whole or in part,
issuing/certifying/managing/using guarantees or similar financial instruments or acquiring/being the beneficiary of such
instruments), credit (loan) servicing (payment of interest and principal), factoring, and receiving interest and credit (principal)
payments on a credit (loan);
d) transactions related to the issue, acquisition, circulation and/or supply (including in the future) of shares in capital, shares,
bonds, certificates, promissory notes and other securities, including transactions carried out to ensure their circulation;
e) issue of funds, securities and/or other financial instruments, their management (including formation of pension and investment
funds or other collective or individual savings plans, and accumulation of financial instruments therein, activities of the asset
management company, insurer and pension company under the Law of Georgia on Voluntary Private Pension), use, placement
(including with the third persons on a guaranteed or non-guaranteed basis), receipt/transfer into nominal holding,
lending/borrowing on temporary (repo) basis, administration, including registration (opening/maintenance of a register), transfer,
blocking/unblocking, encumbering/releasing of encumbrance, other depositary (including of a special depositary) and custodian
(safekeeping and recording) transactions, establishing their fair value, and issue/receipt/management of financial collaterals;
f) acting as a guarantor (including as a third party) for the transaction terms and settlements of financial instruments;
g) corporate transactions, in particular, splitting or consolidation of stocks and shares in capital, increase/reduction of capital
(including issuing, acquiring/alienating and circulating the right of participation in the increase of capital), merger of two or more
legal persons, division of a legal person into two or more legal entities, liquidation of a legal entity, services related to
accrual/accounting for and payment of dividends (in monetary or any other form allowed by law);
h) insurance and/or re-insurance, including the accompanying services provided by an insurance broker and/or an insurance
agent;
i) service of a payment service provider and a payment system operator in accordance with the Law of Georgia on Payment System
and Payment Service;
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j) service directly linked with any financial service/transaction provided for in this paragraph.
3. (Deleted – 14.7.2020, No 6817).
4. In the case of a joint ownership (partnership) provided for by this Code, an owner’s interest in the joint ownership shall be
treated as a financial instrument if no property is attached to it or if the property is not registered in the owner’s name; also, if the
right to a property is registered in advance, the right shall be a financial instrument.
Law of Georgia No 6312 of 25 May 2012 – website, 12.6.2012
Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Article 16 – Supplying goods, delivering services
1. Transfer of title to goods to another person for consideration or free of charge (including sale or exchange of goods,
reimbursement by wages or in kind) shall be deemed as supply of goods.
2. Performance by a person of an action, which is not a supply of goods, for another person on his/her own will, for consideration,
or for free shall be considered provision of services.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 17 – (Deleted)
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Article 18 – Principle of determining the price of goods/services
1. The actual price of goods/services in a transaction shall be used for taxation purposes, unless this Code provides for the
application of a market price or any other price.
2. The market price of goods/services shall be the price formed as a result of interaction of demand for and supply of identical (in
the absence of such – similar) goods/services on the market of goods/services and on the basis of a transaction between the persons
on the relevant market who are not related parties under Article 19 of this Code. The transaction between related parties shall be
taken into account only if the existence of related parties does not affect the results of the transaction.
3. The market price of goods/services shall be determined on the basis of information on transactions made on the market on
identical (similar) goods/services at the moment of supply of these goods/services (in the absence of such, on the calendar day
closest to the moment of sale that precedes or follows, the moment of sale of such goods/services by maximum 30 calendar days),
including the information on the prices fixed at international and other exchanges.
4. The market of goods/services shall be the area of circulation of these goods/services that is determined by a seller's/buyer's
ability to sell/buy, without significant costs, goods/services in the territory nearest to the seller/buyer within or outside the borders
of Georgia.
5. If there is no transaction on identical (similar) goods/services on the market of goods/services or there is no supply of such
goods/services on that market, the market price of goods/services shall be determined by the prices established on the basis of
transactions concluded on identical (similar) goods/services on the calendar day closest to the moment of sale of goods/services.
The calendar day must precede or follow the moment of sale of such goods/services by maximum 30 calendar days.
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6. Where the provisions of paragraphs 1 through 5 of this article cannot apply, the market price of goods/services shall be
established using methods for determining expenditure, possible sales price or receivable benefit.
7. Official sources of information on the market prices of goods/services, the database of the relevant government authorities, the
information submitted to tax authorities by taxpayers, as well as other reliable information shall be used to calculate the market
price of goods/services.
8. From 1 September 2007, when supplying natural gas under the Law of Georgia on Energy and Water Supply, the market price
for tax purposes shall be the price determined (including under the concluded agreement) by the Government of Georgia.
9. Market price of goods/services may be wholesale or retail.
10. An exchange (barter) transaction on goods/services shall be regarded as the sale of goods/services at market price for each party
supplying goods/services, and for each recipient of goods/services an exchange (barter) transaction on goods/services shall be
regarded as the purchase of goods/services at the same market price.
11. A tax authority may apply a market price for taxation purposes, if:
a) a transaction is carried out between related parties except where the existence of related parties does not affect the results of
such transaction;
b) a tax authority proves, in the manner prescribed by the Minister of Finance of Georgia, that the price stated between the parties
to the transaction differs from the actual price;
c) a person delivers goods and/or services to a tourist zone entrepreneur.
12. Identical goods are various goods having similar characteristics, in including physical characteristics, quality, reputation on
market, country of origin and/or manufacturer.
13. Similar goods are various goods, which are not identical but have like characteristics and like component materials, which
enable them to perform the same functions and be commercially interchangeable.
14. For the purposes of paragraph 11(a) of this article, the Minister of Finance of Georgia may specify the cases, where the
existence of related parties does not affect the results of a transaction concluded between them.
15. For the purposes of the eleventh paragraph of this article, the existence of related parties shall be deemed not to have affected
the outcome of a transaction, if the supply of foreign goods between a special trading company and its related party was performed
in a customs warehouse at customs value.
Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 5651 of 20 December 2019 – website, 27.12.2019
Article 19 – Related parties
1. Parties shall be regarded as related if the existence of a special relationship between them may affect the conditions or economic
results of their activity or the activity of the persons that they represent.
2. Special relationships shall be the relationships, where:
a) persons are the founders (participants) of one enterprise, provided their combined share is at least 20%;
b) one person has a direct or indirect interest in another person’s enterprise, provided such participation is at least 20%;
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c) a person controls the enterprise;
d) a natural person is subordinated to another natural person;
e) one person directly or indirectly controls another person;
f) the persons are controlled, directly or indirectly, by a third person;
g) the persons jointly control, directly or indirectly, a third person;
h) the persons are relatives;
i) the persons are members of a partnership.
3. For the purposes of the tax legislation of Georgia, a natural person’s relatives shall be:
a) the first line of relatives: spouse, parent, child, sister, brother;
b) the second line of relatives: spouse, parent, child, sister, brother of each relative in the first line, except for the natural person
who already belongs to the first line;
c) persons who are related to one other as parents and children as a result of long-term guardianship.
4. In determining kinship, step sisters (brothers) shall be treated as equal to full sisters (brothers) and adoptees shall be treated as
equal to biological children. At the same time, guardianship relations shall be regarded as equal to a family unity (where persons
are related to one another as parents and children) which, in turn, shall be deemed equal to kinship relationship. Termination of
family unity between these persons shall not be taken into account if a parent-and-child relationship between them is maintained
under paragraph 3(c) of this article.
5. For the purposes of this article, control shall mean: a supervisory board membership, directorship and the right to appoint
persons to such offices; holding 20% of voting share or interest.
6. For the purposes of this article, a natural person shall be an indirect holder of the interest if his/her relative holds this interest.
SECTION II
TAXPAYERS, TAX AGENTS, ENTERPRISES, ORGANISATIONS, NATURAL PERSONS
Chapter III – Natural Persons, Enterprises, Organisations
Article 20 – Taxpayers, tax agents
1. A taxpayer shall be a person who is obligated to pay taxes provided for by this Code.
2. A tax agent shall be a person who must fulfil a taxpayer's tax obligation in the cases and in the manner provided for by this
Code.
3. For the purposes of this Code, a tax agent shall be treated as equal to a taxpayer.
Article 21 – Enterprise
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1. The following entities conducting or created to conduct economic activities shall be regarded as enterprises:
a) legal entities established under the legislation of Georgia;
b) corporations, companies, firms and similar entities established under the legislation of a foreign country, irrespective of whether
they have legal entity status, as well as a permanent establishment of a foreign enterprise.
c) associations, partnerships and similar entities not provided for in subparagraphs (a) and (b) of this paragraph.
2. An individual entrepreneur shall not be regarded as an enterprise.
Article 22 – Georgian enterprises and foreign enterprises
1. A Georgian enterprise shall be an enterprise whose place of business and/or management is based in Georgia.
2. A foreign enterprise shall be an enterprise that is not a Georgian enterprise under this article.
Article 23 – International company
1. An international company shall be an enterprise of Georgia, which performs activities defined by an ordinance of the
Government of Georgia and earns income solely from these activities.
2. The status of international company shall be granted to an entity by the Government of Georgia.
3. Performance by an international company of the activities not defined by an ordinance of the Government of Georgia shall
entail cancellation of the status of international company for it as of 1 January of the year the activities were commenced.
4. An international company may not be set up within a Free Industrial Zone (FIZ).
5. (Deleted – 14.7.2020, No 6817).
6. (Deleted – 14.7.2020, No 6817).
7. The income earned as a result of working for hire at an international company shall be taxed at 5%.
8. A dividend paid by an international company shall not be taxed at the source and shall not be included in the gross income of a
person receiving the dividend.
9. The object of profit taxation for an international company shall be defined under Article 97(1) of this Code.
10. The profit tax rate for an international company shall be 5%.
11. The amount of taxable profit of an international company shall be calculated by dividing the amount of payment made/cost
incurred according to the object of taxation by 0.95.
12. If the expenses defined by an ordinance of the Government of Georgia are borne in Georgia, an international company may,
under the procedure determined by the Minister of Finance of Georgia, reduce the sum subject to profit taxation by the amount of
the expenses.
13. An international company shall be exempt from property (except for land) tax if that property is intended or used for the
performance of activities allowed by the ordinance of the Government of Georgia.
14. The procedure for communicating information about employees to a tax authority, and for enjoying the privilege provided for
by paragraph 7 of this article shall be established by the Minister of Finance of Georgia.
15. The procedure for granting and cancelling the status of international company for an entity, and the types of activities allowed
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for an international company shall be determined by the Government of Georgia.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
231 – Investment funds
1. An investment fund shall be an enterprise established in accordance with the Law of Georgia on Investment Funds as a joint
investment fund or investment company.
2. On the basis of the Law of Georgia on Investment Funds, activities related to the management and administration of an
investment fund, and the provision of depositary services to an investment fund shall be deemed a financial service.
3. Profit and loss of a joint investment fund shall be deemed the profit and loss of each owner of a joint investment fund unit
beyond the joint investment fund, in proportion to the value of the unit (units) he/she owns. The loss assigned to the owner of a
joint investment fund unit on the basis of this paragraph must not exceed the amount of contribution he/she has paid to the
investment fund and the expenses and commission charges paid to an asset management company.
4. The asset management company of the joint investment fund shall open an investment account for each unit owner under the
procedure established by a joint order of the Ministry of Finance of Georgia and the National Bank of Georgia, and shall keep
records of the profit and loss of a unit owner.
5. Surplus income earned by the owner of a joint investment fund unit by selling or redeeming the unit shall be reduced by as
much as the surplus income included in the taxable income of the same unit owner on the basis of paragraph 3 of this article.
6. Owners of joint investment fund units shall independently keep tax reports. The joint investment fund and its asset
management company shall not be liable to act as a tax agent provided for Article 154 of this Code.
7. Performance of the activity by an owner of a joint investment fund unit or on his/her behalf under the Law of Georgia on
Investment Funds shall not oblige this unit owner to have a permanent institution in Georgia.
8. The profit distributed by a joint investment fund within the activity defined by the Law of Georgia on Investment Funds and
the expenses/paid sums provided for by Article 97(1)(b-d) of this Code shall not be subject to profit taxation.
9. The dividend paid by an investment company to a natural person or a non-resident enterprise shall not be taxed at source and
shall not be included in the gross revenue of a recipient of income.
10. The expenses/paid sums provided for by Article 97(1)(b-d) of this Code envisaged by an investment company within the
activity defined by the Law of Georgia on Investment Funds shall be exempt from profit tax.
11. Distribution of profit by an investment company, if a recipient of dividend is a non-resident or a natural person, shall be taxed
in accordance with Article 97(1)(a) of this Code:
a) at a 15% rate, except as provided for in sub-paragraph b) of this paragraph;
b) at a 5% rate if the investment company makes an investment only in bank deposits and/or financial instruments, except for the
distribution of profit gained from a resident enterprise.
12. The distribution of profit by an investment company to a non-resident or a natural person shall be exempt from profit tax if
the income from which the dividend is paid:
a) does not belong to income received from a Georgian source;
b) belongs to income received by a resident legal person from the sale of the equity securities issued through a public offering in
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Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia;
c) belongs to income received by a resident legal person from the sale of the loan securities issued via a public offering in Georgia
and allowed for trading on an organised market recognised by the National Bank of Georgia, or to income earned as an interest
from the securities;
d) belongs to surplus income received from the sale of the loan securities issued by the Government of Georgia or an international
financial institution, or to income earned as an interest from the securities or from a deposit placed in a banking institution of
Georgia.
13. Surplus income received by a non-resident or a natural person through the supply or redemption of an investment fund unit
shall be taxed:
a) at a 15% rate, except as provided for in sub-paragraph b) of this paragraph;
b) at a 5% rate if the investment fund makes an investment only in bank deposits and/or financial instruments, except when the
investment fund makes an investment in the equities/shares (holds equities/shares) of a resident enterprise.
14. The income shall be exempt from income and profit taxes if it is received:
a) from the sale of an investment fund unit issued through a public offering in Georgia and allowed for trading on an organised
market recognised by the National Bank of Georgia;
b) from the sale of an investment fund unit or the redemption of an investment fund unit if the investment fund makes an
investment only in the deposits placed in banking institutions of Georgia, in the securities issued by the Government of Georgia
and/or an international financial institution, and/or in the loan securities issued by a resident legal person through a public
offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia.
15. For the identification of the profit sum exempt from profit tax under paragraph 12 of this article it shall be deemed that, at the
time of distribution of dividends by the investment company, this sum will be paid out in the first place.
16. For the purposes of paragraphs 2-15 of this article, each sub-fund of an umbrella fund provided for by the Law of Georgia on
Investment Funds shall be deemed an independent investment fund.
17. Apart from the grounds provided for by paragraphs 12 and 14 of this article, additional grounds for the exemption from income
or profit taxation shall be defined in accordance with the general rules established by this Code.
Law of Georgia No 6815 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 24 – (Deleted)
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Article 241 – Special trading company
1. A special trading company shall be a company that has been accorded the status of a special trading company under this article
in order to exempt it from profit tax.
2. The status of a special trading company may be accorded at the time of registration only to a company that is set up for that
purpose, for the current and following calendar years. When granting the status of a special trading company, a certificate
confirming the status shall be issued. A foreign enterprise conducting economic activity through a permanent establishment in
Georgia may additionally register a separate permanent establishment in order to acquire the status of a special trading company
and to conduct only those activities that are permitted by this article.
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3. The status of a special trading company shall be accorded to an enterprise by a tax authority. The procedure for according the
status of a special trading company shall be determined by an order of the Minister of Finance of Georgia.
4. An enterprise having the status of a special trading company may:
a) re-export foreign goods from a customs warehouse;
b) supply foreign goods in a customs warehouse both to special trading companies and other enterprises that do not have the status
of a special trading company;
c) purchase foreign goods from enterprises that do not have a special trading company status at not less than their customs value
for subsequent re-export and/or supply in a customs warehouse;
d) in addition to the income earned from the activities referred to in subparagraphs (a) – (c) of this paragraph, earn other income,
including:
d.a) income that is exempt from profit tax under this Code;
d.b) income from the supply of fixed assets used by the special trading company for economic activity for over two years;
d.c) income, other than that referred to in subparagraphs (d.a) and (d.b) of this paragraph, which from a Georgian source,
according to a tax period (year) must not exceed GEL 1 000 000 and 5% of the customs value of the foreign goods brought by such
company into Georgia.
5. An enterprise having the status of a special trading company may not:
a) import goods into Georgia, other than goods intended as fixed assets of the company;
b) buy Georgian goods within the territory of Georgia for subsequent supply;
c) deliver services to a Georgian enterprise/individual entrepreneur and/or permanent establishment of a foreign enterprise in
Georgia;
d) have a customs warehouse.
6. If a taxpayer buys foreign goods from a special trading company, the costs deductible by the buyer from the total annual income
shall not exceed the customs value of such goods. That restriction shall not apply to the costs incurred by the buyer, which under
this Code are attributed to the value of the asset and are not related to the payments made to the special trading company.
7. The status of a special trading company shall be cancelled for that calendar year which the authorised representative of the
company indicates in an application for cancellation of the status of a special trading company. The application has to be submitted
not later than five business days before commencement of the relevant year.
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Article 242 – A special enterprise
1. A special enterprise shall be a person who has been granted the status of special enterprise under this article.
2. A person having the status of special enterprise may, along with the activities permitted by the legislation of Georgia, with the
special consent under Article 6(2) of the Law of Georgia on Occupied Territories, conduct the following activities:
http://www.matsne.gov.ge 20000000005001016012
a) supply of goods originated or produced in the occupied territory of Georgia from the mentioned territory to another territory of
Georgia, and/or their placement under the export procedure from the territory of Georgia (except for the occupied territory of
Georgia), in accordance with law. In the case under this subparagraph, supply of excise goods (except for alcoholic beverages and
tobacco products) shall be prohibited;
b) supply of Georgian goods (except for goods originated or produced in the occupied territory of Georgia) to the occupied
territory of Georgia;
c) production of goods in the occupied territory of Georgia solely for the purpose under subparagraph a) of this paragraph.
3. The status of special enterprise shall be granted to a person by a tax authority.
4. A person having the status of special enterprise may supply the goods under paragraph 2(a) and (b) of this article only:
a) within/from the territory of the Autonomous Republic of Abkhazia – from/to Zugdidi municipality;
b) within/from the territory of Tskhinvali region (former Autonomous Region of South Ossetia) – from/to Gori municipality.
5. Procedures for granting the status of special enterprise to and revoking it for a person, for identifying the goods originated or
produced in the occupied territory of Georgia, and the operating procedures for a person having this status shall be determined by
the Government of Georgia.
Law of Georgia No 2476 of 6 June 2018 – website, 21.6.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 25 – Free Industrial Zone Enterprise
1. A Free Industrial Zone Enterprise (‘FIZ Enterprise’) shall be a company established under the Law of Georgia on Free Industrial
Zones.
2. If a FIZ Enterprise supplies goods to a person (other than a FIZ Enterprise) registered under the legislation of Georgia, the FIZ
Enterprise shall pay 4% of the revenue received/receivable from the supply of such goods (if the supply of goods is made free of
charge – 4% of the market price of such goods) not later than the 15th day of the month following the month in which the goods
are supplied.
3. If a person (other than a FIZ Enterprise) registered under the legislation of Georgia supplies goods (other than electricity, water
and natural gas intended for local consumption and/or production) to a FIZ Enterprise, the FIZ Enterprise shall pay 4% of the
market price of the supplied goods not later than the 15th day of the month following the month in which the goods are supplied.
4. If a person (other than a FIZ Enterprise) registered under the legislation of Georgia delivers goods to a FIZ Enterprise, the
market price of the supplied goods shall be used for taxation purposes.
5. A FIZ Enterprise may not:
a) purchase services from a person (other than a FIZ Company) registered under the legislation of Georgia, except for:
a.a) security services and/or services related to letting or leasing out property provided by an organiser and/or administration of
the Free Industrial Zone;
a.b) transport, communication, sewage, audit and/or consulting services, execution of financial transactions and/or delivery of
financial services by a licensed financial institutions, as well as services relating to installation, assembly and/or construction of
fixed assets.
a.c) services as determined by the Government of Georgia.
b) delivering services to a person (other than a FIZ Enterprise) registered under the legislation of Georgia.
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6. Tax reporting rules for FIZ Enterprises shall be determined by an order of the Minister of Finance of Georgia.
7. The Government of Georgia shall be entitled to determine the types of services to be provided to non-resident persons (except
for permanent offices of non-resident persons in Georgia) by FIZ Enterprises, which, for the purposes of taxation, shall be deemed
as permitted activities carried out by FIZ Enterprises in the free industrial zone.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 4680 of 18 December 2015- website, 29.12.2015
Article 26 – (Deleted)
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 261 – Tourist enterprise
1. A tourist enterprise shall be a legal person that builds a hotel, supplies hotel assets/part of the assets to another person (with or
without the right to buy back the assets), and on the basis of a commutative contract (including on the basis of a lease, right of use,
right of administration, trusteeship, intermediary and/or other contract terms) concluded with the buyer of this property ensures
that the hotel assets/ part of the assets are used as hotel rooms/apartments.
2. After the completion of the hotel construction, a tourist enterprise shall:
a) designate a fixed amount of space to be used for hotel rooms/apartments;
b) make sure that during a maximum of 10 calendar years after the acceptance of the building (hotel) for operation, the total
(including amounts additionally charged by the tax authority with respect to the given facility in the relevant period) VAT taxable
turnover (other than transactions exempt from VAT) from a specific facility (hotel) declared by a tourist enterprise and/or by a
person(s) invited under a relevant agreement for the functioning/operation of the facility/part of the facility as a hotel, is not less
than the amount obtained as a result of dividing the turnover exempt from VAT with the right of deduction defined by Article
172(4)(v) of this Code as a result of supplying the hotel assets/part of assets by 1.18.
3. The status of tourist enterprise shall be granted to a person by the Revenue Service according to a specific facility (hotel). The
Revenue Service may request the tourist enterprise to present guarantees, the value of which must not exceed 18% of the amount
obtained as a result of dividing the turnover exempt from VAT with the right of deduction under Article 172(4)(v) of this Code.
4. The procedure for awarding the status of a tourist enterprise to a person, the procedure for its operation and cancellation, as
well as the minimum amount of space from the total space of the building to be used as hotel rooms/apartments according to the
municipalities shall be determined by the Government of Georgia.
Law of Georgia No 5791 of 13 March 2012 – website, 23.3.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
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Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 262 – (Deleted)
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 5627 of 19 December 2019 – website, 26.12.2019
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 263 – Pharmaceutical enterprise
1. A pharmaceutical enterprise shall be a legal person producing and supplying pharmaceutical products in Georgia.
2. The status of pharmaceutical enterprise shall be granted to a person by the Government of Georgia.
3. The procedure for granting the status of pharmaceutical enterprise to a person, for operating and cancelling it shall be defined
by an ordinance of the Government of Georgia.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 27 – Place of business of an enterprise
1. A place of business of an enterprise shall be the place of its state registration, and in the absence of such place, the legal address
indicated in the founding documents (charter, agreement, regulations) of the enterprise.
2. If an enterprise conducts business without state registration and its founding documents do not specify a place of business of the
enterprise, the place of business of the enterprise shall be its principal place of business. The principal place of business of an
enterprise shall be determined by a tax authority on the basis of data submitted by the enterprise. If the enterprise fails to submit
such data or presents questionable data, a tax authority shall determine the principal place of business of the enterprise on the basis
of available information.
3. If no relevant information is available and the principal place of business of an enterprise cannot be determined, the place of
business of an enterprise shall be the place of management of the enterprise.
4. The place of business of an enterprise provided for in Article 21(1)(c) of this Code shall be the place of business of the party to
the agreement who is responsible for managing the business affairs under the joint activities agreement. If one of the parties to an
agreement is a Georgian enterprise or a resident natural person, that party shall keep record of the results of the joint activities for
taxation purposes, irrespective of who is responsible for managing the business affairs. If business affairs are not managed by one or
several parties to the joint activities agreement but rather jointly by all the parties to the agreement, the place of business of the
enterprise shall be the place of business of the Georgian enterprise participating in the joint activities agreement. If the parties to
the joint activities agreement are only resident natural persons who jointly run the business, the place of business of the enterprise
shall be determined by a tax authority on the basis of data presented by the parties to the joint activities agreement. If the parties
to the joint activities agreement do not submit such data or present questionable data, a tax authority shall determine the place of
business on the basis of available information.
Article 28 – Place of management of an enterprise
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1. The place of management of an enterprise shall be place of effective management of the enterprise, i.e. the place where, under
the founding documents (charter, agreement, regulations) of the enterprise, the board of directors (or any other management
body) of the enterprise exercises managerial functions irrespective of the place of business of the enterprise’s top controlling bodies
or the place of receipt of income from its activities, unless otherwise provided for in this article.
2. The place of management of an enterprise provided for in Article 21(1)(c) of this Code shall be the place of business of the
enterprise.
3. If an enterprise is managed by a manager (another enterprise or natural person) who acts under an agreement or resolution of
appointment, the place of management of the enterprise shall be the place of business of the managing enterprise or the place of
residence of the managing natural person, respectively. The place of management of an enterprise shall be determined similarly if
the enterprise is actually managed by another enterprise or natural person without a relevant agreement or resolution.
4. If an enterprise has no management body or the management body of an enterprise has no permanent place of business or if the
manager does not directly manage the enterprise, the place of management of the enterprise shall be the place of business of the
management body (administration, directorate, board of directors, central accounting office or other similar body) of the
enterprise.
Article 29 – Permanent establishment
1. A permanent establishment of a foreign enterprise or of a non-resident natural person in Georgia is a fixed place of business
through which the economic activity of the entity is wholly or partly carried on in Georgia, including the activity of an authorised
agent, except as provided for by the sixth, ninth and twelfth paragraphs of this article.
2. The following shall be treated as equal to a permanent establishment:
a) a construction site, installation or construction project and the controlling activities related to them;
b) installation or constructions, drilling rig or vessels used for prospecting minerals, and the controlling activities related to them;
c) a permanent base where a non-resident natural person carries on economic activity;
d) a place of management, branch, representative office, department, bureau, office, agency, workshop, mine or quarry or any
other place of extraction of natural resources, or any other subunit or any other place of business of a foreign enterprise.
3. The provisions of the first and second paragraphs of this article shall not apply to the services rendered by non-resident
subcontractors in performing oil and gas operations under the Law of Georgia on Oil and Gas.
4. Notwithstanding the provisions of the first and second paragraphs of this article, a permanent establishment of a foreign
enterprise in Georgia shall be the management of this enterprise by another person (another enterprise, subunit of this or of
another enterprise or by a natural person who is not the person specified in the fifth paragraph of this article) on behalf and/or in
the interest of the enterprise for over three months, except as provided for in the sixth and fifth paragraphs of this article.
5. If a foreign enterprise or a non-resident natural person carries on economic activity in Georgia through a professional
intermediary, agent or broker as prescribed by law and if such intermediary, agent or broker is not authorised to conduct
negotiations or sign agreements on behalf of the foreign enterprise or non-resident natural person, then the activity of the
intermediary, agent or broker shall not constitute a permanent establishment of the foreign enterprise or non-resident natural
person in Georgia.
6. Mere possession by a foreign enterprise or non-resident natural person of securities or shares in the capital of a Georgian
enterprise or of any property on the territory of Georgia shall not constitute a permanent establishment of the foreign enterprise
or non-resident natural person in Georgia if such possession does not have the characteristics of a permanent establishment set
forth in the first and second paragraphs of this article.
7. The mere fact of secondment of staff by a foreign enterprise to another enterprise or organisation based in the territory of
Georgia shall not constitute a permanent establishment of the foreign enterprise or non-resident natural person in Georgia,
provided that the employees are under the control of the enterprise or organisation to which they were seconded.
8. The mere control by a foreign enterprise or non-resident natural person of a Georgian enterprise or a Georgian organisation
http://www.matsne.gov.ge 20000000005001016012
shall not constitute a permanent establishment of the foreign enterprise or non-resident natural person in Georgia.
9. A permanent establishment of a foreign enterprise or non-resident natural person in Georgia shall not include an establishment
in the territory of Georgia that is used only for:
a) storing or displaying goods belonging to the foreign enterprise or non-resident natural person;
b) storing a stock of goods belonging to the foreign enterprise or non-resident natural person so that another person could process
it;
c) purchasing goods or gathering information for the foreign enterprise or non-resident natural person;
d) performing preparatory or any other ancillary activity in the interests of the foreign enterprise or non-resident natural person;
e) preparing and/or signing agreements on granting loans, supplying goods or providing technical services on behalf of the foreign
enterprise or non-resident natural person.
f) conducting any combination of the activities set forth in subparagraphs (a)-(e) of this paragraph.
10. A permanent establishment of a foreign enterprise or of a non-resident natural person in Georgia shall be deemed as such from
the moment when it is registered under the eleventh paragraph of this article, is granted appropriate powers or commences
representative activity.
11. The obligation to register a permanent establishment of a foreign enterprise or of a non-resident natural person in Georgia
shall rest with a tax authority, which shall maintain the relevant register. The registration procedure and the procedure for
maintaining the register shall be determined by the Minister of Finance of Georgia.
12. The mere transfer of property by a foreign enterprise or non-resident natural in the territory of Georgia by lease, usufruct,
rent, letting and/or any other similar form shall not constitute a permanent establishment of this foreign enterprise or non-
resident natural person in Georgia, except where a person systematically performs, in person, through a representative or hired
personnel, the service and supervision of the activities of the property recipient.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 30 – Organisations
1. The following entities shall be regarded as organisations:
a) non-entrepreneurial (non-commercial) legal persons, public or religious organisations (associations), institutions that are non-
entrepreneurial (non-commercial) legal persons established or acting under the legislation of Georgia or under the legislation of a
foreign country; also Georgian-based branches and other similar sub-units of the organisations established under the legislation of
a foreign country, through which these organisations conduct business, wholly or partly, (including the activity of an authorised
agent), also budgetary organisations, legal entities under public law, corporations, institutions;
b) international (inter-state, inter-governmental, diplomatic) organisations – organisations, diplomatic missions and consular
offices, or foreign non-entrepreneurial organisations governed by international law.
2. A place of business and a place of management of an organisation shall be determined according to procedures established for
enterprises by this Code.
3. An organisation shall be deemed as a Georgian organisation or as a foreign organisation according to procedures established for
enterprises by this Code.
4. If an organisation conducts economic activity, the part of its property and activity that is directly related to its economic activity
shall be deemed to be the property and activity of the enterprise, and where such distinction cannot be made, the property and
activity related to the economic activity of an organisation shall be calculated according to the specific share of the income from
economic activity in the income earned by the organisation.
Law of Georgia No 6439 of 12 June 2012 – website, 22.6.2012
http://www.matsne.gov.ge 20000000005001016012
Article 31 – Budgetary organisations
A budgetary organisation is an organisation defined in Article 6(r) of the Budget Code of Georgia.
Law of Georgia No 5173 of 28 October 2011 – website, 7.11.2011
Law of Georgia No 2938 of 12 December 2014 – website, 24.12.2014
Article 32 – Charitable organisations
1. A charitable organisation shall be an organisation that has been accorded with the status of a charitable organisation under this
article.
2. The status of a charitable organisation shall be accorded to an organisation that is established to carry out charitable activity, is
registered in a prescribed manner, has at least one year experience in charitable activity and complies with the requirements set
forth in this article.
3. Ancillary economic activity that serves the main purposes of an organisation shall not change the organisation’s charitable
character.
4. The status of a charitable organisation is accorded, cancelled and deprived by the Head of the Revenue Service in agreement
with the Minister of Finance of Georgia upon a recommendation of the relevant tax authority.
5. The status of a charitable organisation is accorded on the basis of a written application of the organisation. The application shall
indicate the following information on the organisation:
a) name;
b) organisational and legal form;
c) main goals;
d) main areas of activity in the last year;
e) addresses of the management body and of branches.
6. The following shall be attached to the application:
a) a copy of the charter of the organisation
b) a copy of the civil and/or tax registration certificate
c) an activity report for the last year, including the description of activities (projects, services)
d) the last year’s financial documents (balance sheet and income statement) certified by an independent auditor.
7. The Head of the Revenue Service shall make a reasonable decision in connection with the application within one month. If no
decision is made within this period, the status shall be deemed to have been accorded. The status shall be accorded permanently.
The status shall take effect upon being accorded.
8. An organisation that has been accorded with this status shall be given a certificate confirming the status. The certificate shall
indicate:
a) name and organisational and legal form of the organisation
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b) status
c) address of the management body
d) date of according the status and the status number
e) identification number of the organisation.
9. Upon obtaining the status, the organisation shall undertake the obligations and responsibilities provided under this Code. In
particular, before 1 April each year a charitable organisation shall file with the relevant tax authority:
a) a program report on its last year's activity, which shall include a description of the activity (including economic activity);
b) a financial report on earned revenues, indicating sources and the purpose of the expenditure;
c) last year’s financial documents (balance sheet and income statement) certified by an independent auditor.
10. The program report of the last year's activity and last year’s financial documents (balance sheet and income statement) shall be
published and made available for all interested persons.
11. The profits and assets of a charitable organisation shall not be distributed among its members, founders, board of directors or
supervisory board members. If a charitable organisation is liquidated, its property shall be transferred to a charitable organisation
with similar goals under a decision of an authorised body or person, or if no such organisation exists, the property shall be
transferred to another charitable organisation. If a legal entity under public law having the status of a charitable organisation was
established on the basis of state property, in the case of its liquidation its assets shall be transferred to the state.
12. The status of a charitable organisation shall be cancelled:
a) on the initiative of the organisation;
b) if the status has been deprived.
13. A charitable organisation shall be deprived of its status if:
a) it fails to comply with the requirements of this Code;
b) its state and/or tax registration has been cancelled.
14. If the status is deprived for non-compliance with the requirements of this Code, the charitable organisation shall return that
part of profits received as a result of tax privileges due to the status, which is related to non-compliance with the above
requirements.
15. If a charitable organisation does not comply with the requirements of this Code, before submitting to the Revenue Service an
application for depriving the charitable organisation of its status, a tax authority shall send the charitable organisation a notice,
setting an additional one-month period for the fulfilment of the requirements of this Code.
16. A charitable organisation that has been deprived of its status may apply for restoration of the status not earlier than one year
after eliminating the cause for deprivation of the status.
17. The Revenue Service shall maintain the Unified Register of Charitable Organisations. The Register shall specify:
a) name of the organisation;
b) addresses of the management body, branches and representations;
c) main goals;
d) date of according the status and the status number;
e) identities and addresses of all members of the management body.
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18. If any of the data entered into the Unified Register of Charitable Organisations is changed, the organisation shall notify the
relevant tax authority in writing of such changes as soon as they occur.
19. The Unified Register of Charitable Organisations shall be available for any interested person.
Article 33 – Religious organisations
A religious organisation shall be an organisation established for conducting religious activity and registered as such in the
prescribed manner.
Article 34 – Resident natural persons and non-resident natural persons in Georgia
1. Natural persons shall be:
a) citizens of Georgia;
b) foreign citizens;
c) stateless persons.
2. A Georgian resident for the entire current tax year shall be a natural person who has actually stayed in the territory of Georgia
for 183 or more days in any continuous 12-calendar-month period ending in that tax year, or a natural person who was in a
foreign country in the public service of Georgia during that tax year.
3. The time of actual stay in the territory of Georgia shall be the time, during which a natural person stayed in Georgia, as well as
the time he/she spent outside Georgia specifically for treatment, leisure, business trip or education.
4. The time of actual stay in the territory of Georgia shall not include the time, during which a natural person stayed in Georgia:
a) as a person having a diplomatic or consular status or as a family member of such person;
b) as an employee of an international organisation acting under an international agreement of Georgia or as a person in the public
service of a foreign country in Georgia or as a family member of such person, other than Georgian citizens;
c) when moving from one foreign country to another via the territory of Georgia;
d) for treatment or leisure.
5. The day of actual stay in the territory of Georgia shall be the day, during which a natural person stayed in Georgia irrespective
of the length of the stay.
6. Georgian residency, except as provided for in paragraph 2 of this article, may be accorded to a high net worth individual under
the procedure and conditions determined by the Minister of Finance of Georgia. A high net worth individual shall be a person as
defined by the Law of Georgia on Securities Market.
61. If the residency of a natural person cannot be established in relation to any country, such natural person shall be deemed to be
a Georgian resident if he/she applies to a tax authority, provided he/she is a Georgian citizen.
62. The residency of Georgia, except for cases provided for in paragraphs 2, 6 and 61 of this article, may be granted to a foreign
natural person in the case and under the procedure defined by the Minister of Finance of Georgia.
7. A non-resident in Georgia shall be a person who is not a resident under this article.
8. The status of a resident or of a non-resident is established for each tax period. At the same time, the days, according to which
the natural person was deemed as a resident in the previous tax period, shall not be taken into account in establishing the status of
residency in the following tax periods.
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Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 35 – Place of residence and place of actual stay of a natural person
1. A place of residence of a natural person shall be the person’s usual place of residence or the place of his/her actual stay unless
otherwise provided for by this article.
2. A place of residence of a minor shall be the place of residence of the person having parental rights with respect to the minor,
and a place of residence of the person who has a guardian or custodian shall be the place of residence of the guardian or custodian.
3. A place of actual stay of a natural person shall be the place of his/her temporary residence, unless otherwise provided for in this
article.
4. A place of actual stay of military personnel, also of persons permanently relocating due to the nature or conditions of their job
shall be the place where they actually live or are registered in the prescribed manner (including, the place of deployment of
military units or the location of the respective enterprise).
5. If a natural person has several residences (homes or other residence), his/her place of residence or place of actual stay shall be
determined by a tax authority in agreement with the natural person.
Article 36 – Entrepreneur natural person and his/her place of business
1. The following persons shall be deemed an entrepreneur natural person:
a) an individual entrepreneur – a natural person if he/she is an individual entrepreneur under the Law of Georgia on
Entrepreneurs;
b) a natural person if he/she is engaged in an activity provided for by Article 3(1 and 2) of the Law of Georgia on Entrepreneurs.
2. If the natural person defined in the first paragraph of this article performs economic activity without registration, license or
permit, this shall not serve as the basis for not recognising this natural person as an entrepreneur natural person for taxation
purposes.
3. The place of business of an entrepreneur natural person shall be the place of his/her economic activity.
Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021
Article 37 – Taxpayer’s representative
1. A taxpayer may participate in tax matters through its legal or authorised representative. Personal participation of a taxpayer in
tax matters shall not deprive it of the right to have a representative, nor shall the participation of the representative deprive it of
the right to personally participate in the said relations.
2. Legal representatives of an enterprise/organisation shall be its bodies and/or other authorised persons under the legislative acts
of Georgia or foundation documents of the enterprise/organisation. A legal representative of a natural person shall be the person
who exercises relevant rights under this Code and other legislative acts of Georgia.
3. An action of a taxpayer’s legal representative, in particular the participation of the representative in tax matters, shall be deemed
the action of the taxpayer.
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4. A taxpayer’s legal representative shall be a person who is authorised by the taxpayer to represent its interests before tax
authorities and/or in dealings with other participants of tax matters or in court.
5. An authorised representative of an enterprise/organisation shall act under a power of attorney granted by that
enterprise/organisation, and the authorised representative of a natural person shall act under a notarised power of attorney granted
by that natural person or under any other document deemed equal to a power of attorney under the Civil Code of Georgia, within
the scope of such power of attorney or other document.
Chapter IV – Legal Protection of Taxpayers
Article 38 – Right to request information
1. Taxpayers may obtain from tax authorities information on the application of the tax legislation of Georgia, on protection of
taxpayer’s rights, and may access information on them in the possession of tax authorities.
2. Taxpayers may withhold from law-enforcement and other controlling authorities, other than tax authorities, documents related
to the determination of objects of taxation, computation and payment of taxes, except where such powers are granted to other
authorities under this Code.
Article 39 – Tax secret
1. Any information received by a tax authority on a taxpayer (except for the information specified in paragraph 11 of this article)
shall be the tax secret.
11. The following information on a tax payer shall not be a tax secret and shall be public:
a) information on registration as a tax payer;
b) information on registration as a VAT payer;
c) the status;
d) the name;
e) legal form;
f) the address;
g) the identification number;
h) the date of granting the identification number;
i) the registering body;
j) tax arrears;
k) the persons with the right of representation/administration;
l) the founders;
m) information on the tax lien/the right of pledge and on the seizure of property;
n) other public information registered in the Registry of Entrepreneurs and Non-Entrepreneurial (Non-Commercial) Legal
Entities;
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o) public information registered in the Registry of Citizens’ Political Unions (Parties);
p) about the restriction of using (including the suspension of making out/issuing) a tax invoice for a person.
2. A tax authority, its employee, invited expert and/or expert shall protect the confidentiality of taxpayer information that became
known to them in the performance of official duties. They may disclose personally identifiable information on certain taxpayers
only to the following persons:
a) employees of the system of the Ministry of Finance of Georgia and members of the Council of Tax Appeals within the Ministry
of Finance of Georgia – in order for them to fulfil their official duties;
b) law-enforcement authorities – in connection with the criminal cases prosecuted by them;
b1) (Deleted – 17.12.2025, No 1296);
b2) the Ministry of Internal Affairs of Georgia – for exercising powers provided for by the legislation of Georgia;
c) court – to determine tax obligations or liabilities of a taxpayer in connection with a case pending in the court;
d) a competent body of a foreign state – under an international agreement of Georgia;
e) the Legal Entity Under Public Law (LEPL) within the Ministry of Justice of Georgia – National Bureau of Enforcement)
(‘National Bureau of Enforcement’) and to a private enforcement officer – in the course of executing decisions under the Law of
Georgia on Enforcement Proceedings and/or in exercising the powers provided for in an agreement between a tax authority and
National Bureau of Enforcement;
f) the National Statistics Office of Georgia (GeoStat) – under procedures established by the Government of Georgia;
g) the State Audit Office, for exercising the power provided for by the Organic Law of Georgia on State Audit Office;
h) the Legal Entity under Public Law (LEPL) within the Ministry of Justice of Georgia – National Agency of Public Registry
(‘National Agency of Public Registry’) – in exercising the powers under an agreement between a tax authority and the National
Agency of Public Registry;
i) persons determined by the Government of Georgia, to inform a taxpayer of its tax arrears as prescribed by the Minister of
Finance of Georgia;
j) (Deleted – 1.5.2015, No 3581);
k) the Legal Entity under Public Law (LEPL) within the Ministry of Justice of Georgia – Public Service Development Agency – in
exercising powers provided for by the legislation of Georgia;
l) the Legal Entity under Public Law (LEPL) – Financial Monitoring Service of Georgia – in exercising powers provided for by the
legislation of Georgia;
m) the state sub-agency institution of the Ministry of Environment and Agriculture of Georgia – the Environmental Supervision
Department, in exercising powers provided for under the legislation of Georgia; also, to the Legal Entity under Public Law (LEPL)
within the Ministry of Environment and Agriculture of Georgia – the Nuclear and Radiation Safety Agency, and to the Standing
Commission for Military-Technical Issues of the Ministry of Defence of Georgia – the information provided for under the Law of
Georgia on Nuclear and Radiation Safety;
m) the state sub-agency institution of the Ministry of Environment and Agriculture of Georgia – the Environmental Supervision
Department, in exercising powers provided for under the legislation of Georgia; also, to the Legal Entity under Public Law (LEPL)
within the Ministry of Environment and Agriculture of Georgia – the Nuclear and Radiation Safety Agency, and to the Standing
Commission for Military-Technical Issues of the Ministry of Defence of Georgia – the information provided for under the Law of
Georgia on Radiation Protection, Nuclear Safety and Security;
n) the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia and to
administrative bodies within its system – for exercising the rights and duties under the legislation of Georgia;
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o) the Legal Entity under Public Law (LEPL) – the Georgian Competition and Consumer Agency – in exercising powers provided
for by the legislation of Georgia;
p) the Legal Entity under Public Law (LEPL) within the Ministry of Environment and Agriculture of Georgia – the National Food
Agency – under the procedure prescribed by the Government of Georgia;
q) (Deleted – 17.12.2025, No 1282);
r) the Legal Entity under Public Law operating under the Ministry of Justice of Georgia – the Digital Governance Agency – in
order for the Agency to forward the said information to the State Audit Office, for exercising powers under the Law of Georgia on
the Fight against Corruption and subordinate legal acts issued on its basis, for operating the electronic data exchange system;
s) the Legal Entity under Public Law operating under the Ministry of Justice of Georgia – the Digital Governance Agency –
information necessary for the operation of the electronic exchange system of documentation between the entities engaged in the
international commerce;
t) the Ministry of Environment and Agriculture of Georgia, information under the Law of Georgia on Waste Import, Export and
Transit;
u) (Deleted – 5.7.2018, No 3109);
v) the Legal Entity under Public Law within the Ministry of Environmental Protection and Agriculture of Georgia – the National
Agency for Mineral Resources, in exercising powers defined by the legislation of Georgia;
w) the Legal Entity under Public Law – the Pension Fund of Georgia, for exercising powers under the Law of Georgia on Funded
Pension and subordinate normative acts of Georgia issued on the basis thereof;
w1) the Legal Entity under Public Law – the Insurance State Supervision Service of Georgia, for exercising powers under the Law
of Georgia on Voluntary Private Pension and subordinate normative acts of Georgia issued on the basis thereof;
w2) the insurer, the asset management company and the pension company defined by the Law of Georgia on Voluntary Private
Pension, for exercising powers under the same law and subordinate normative acts of Georgia issued on the basis thereof;
x) the Legal Entity under Public Law within the system of the Ministry of Economics and Sustainable Development of Georgia –
the Market Surveillance Agency, in exercising the power under the legislation of Georgia;
y) the Ministry of Justice of Georgia, for exercising the power of an agent of the state, as vested in it by the legislation of Georgia,
in the arbitration or a foreign court, and the power of an agent of the state in an international court, in particular in the European
Court of Human Rights, in the Human Rights Committee set up on the basis of the United Nations International Covenant on
Civil and Political Rights and in the committees set up on the basis of other United Nations conventions, and in the United
Nations International Court of Justice;
z) to ensure control of the legal regime of the Georgian maritime space, the Joint Maritime Operations Centre of the executive
authorities of Georgia related to the protection of the national border control entities and the national boundary regime, in
exercising the power defined by the legislation of Georgia;
z1) the Legal Entity under Public Law (LEPL) subject to the control of the Ministry of Internally Displaced Persons from the
Occupied Territories, Labour, Health and Social Affairs of Georgia – the Labour Inspection Service, in exercising powers provided
for by the legislation of Georgia;
z2) the Legal Entity under Public Law (LEPL) within the system of the Ministry of Economy and Sustainable Development of
Georgia – the Land Transport Agency, in exercising powers provided for by the legislation of Georgia;
z21) a structural unit of the city hall, a natural person or a legal entity defined by a representative body of Tbilisi municipality, for
considering administrative offence cases provided for by Article 1352 of Administrative Offences Code of Georgia;
[z3) the Legal Entity under Public Law (LEPL) – the State Procurement Agency, in exercising powers provided for by the Law of
Georgia on Public Procurement;
z4) the Public Procurement-related Dispute Resolution Council – in exercising powers provided for by the Law of Georgia on
http://www.matsne.gov.ge 20000000005001016012
Public Procurement. (Shall become effective from 1 January 2030)]
z5) in accordance with the rule defined by an ordinance of the Government of Georgia, a property rights collective management
organisation defined by Article 63(2) of the Law of Georgia on Copyright and Related Rights, which has the authority under
Article 21(3) of the same Law and acts in compliance with the ordinance of the Government of Georgia.
z6) the Administration of the Government of Georgia, for fulfilling the function of facilitating control of the implementation of
decisions provided for by the Law of Georgia on the Structure, Powers and Procedure for Activity of the Government of Georgia.
z7) the Ministry of Defence of Georgia, for controlling the compliance with the terms and conditions of the permit provided for by
the Laws of Georgia on Arms, on the Control of Military and Dual-use Goods and on Licences and Permits, within the scope of its
competence.
3. Employees of a tax authority shall protect the confidentiality of information obtained in the course of their official duties, and
shall not use it for personal goals or disclose it to another person. Such actions shall be regarded as disclosure of a tax secret. The
loss of documents containing a tax secret or disclosure of such information shall carry liability under the legislation of Georgia.
31. Legal entities under public law referred to in paragraph 2(o) and (p) of this article and their employees, who have received
information specified in this article may not divulge such information.
4. Information held by a tax authority and containing a tax secret shall be stored and processed in a special manner. Only
authorised officials designated by the Minister of Finance of Georgia under the procedure established by the same ministry may
have access to the information containing a tax secret.
5. If there is a written/electronic permission of a taxpayer, information on the taxpayer may be communicated to another person.
Publication and/or dissemination by the taxpayer of this information in the mass media shall be deemed as the taxpayer’s
permission for a tax authority to communicate information to a third party within the scope of the above information.
6. This article shall not apply to the public notice provided for in Article 44 of this Code or the information spread by the Revenue
Service about persons who conduct economic activity with false tax documents.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6330 of 25 May 2012 – website, 8.6.2012
Law of Georgia No 6317 of 25 May 2012 – website, 19.6.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 6444 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 6550 of 22 June 2012 – website, 29.6.2012
Law of Georgia No 491 of 25 March 2013 – website, 5.4.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2160 of 21 March 2014 – website, 27.3.2014
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 3613 of 28 May 2015 – website, 4.6.2015
Law of Georgia No 3673 of 29 May 2015 – website, 4.6.2015
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Law of Georgia No 4368 of 27 October 2015 – website, 11.11.2015
Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015
Law of Georgia No 4493 of 11 November 2015 – website, 24.11.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 4958 of 13 April 2016 – website, 26.4.2016
Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016
Law of Georgia No 195 of 22 December 2016 – website, 29.12.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1701 of 7 December 2017 – website, 14.12.2017
Law of Georgia No 3109 of 5 July 2018 – website, 11.7.2018
Law of Georgia No 3308 of 21 July 2018 – website, 6.8.2018
Law of Georgia No 3279 of 21 July 2018 – website, 9.8.2018
Law of Georgia No 3383 of 5 September 2018 – website, 24.9.2018
Law of Georgia No 4260 of 27 December 2018 – website, 29.12.2018
Law of Georgia No 4599 of 8 May 2019 – website, 8.5.2019
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5691 of 20 December 2019 – website, 26.12.2019
Law of Georgia No 5758 of 17 March 2020 – website, 23.3.2020
Law of Georgia No 6301 of 12 June 2020 – website, 26.6.2020
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 7132 of 16 September 2020 – website, 21.9.2020
Law of Georgia No 7183 of 29 September 2020 – website, 5.10.2020
Law of Georgia No 1148 of 16 December 2021 – website, 27.12.2021
Law of Georgia No 1331 of 30 December 2021 – website, 13.1.2022
Law of Georgia No 1384 of 16 February 2022 – website, 23.2.2022
Law of Georgia No 2214 of 30 November 2022 – website, 15.12.2022
Law of Georgia No 2285 of 1 December 2022 – website, 15.12.2022
Law of Georgia No 2578 of 9 February 2023 – website, 27.02.2023
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3290 of 16 June 2023 – website, 6.7.2023
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Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3759 of 29 November 2023 – website, 11.12.2023
Law of Georgia No 3865 of 15 December 2023 – website, 25.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 4324 of 27 June 2024 – website, 12.7.2024
Law of Georgia No 4427 of 5 September 2024 – website, 23.9.2024
Law of Georgia No 561 of 13 May 2025 – website, 16.5.2025
Law of Georgia No 1055 of 12 November 2025 – website, 17.11.2025
Law of Georgia No 1074 of 25 November 2025 – website, 27.11.2025
Law of Georgia No 1282 of 17 December 2025 – website, 18.12.2025
Law of Georgia No 1296 of 17 December 2025 – website, 23.12.2025
Law of Georgia No 1713 of 10 June 2026 – website, 15.6.2026
Law of Georgia No 1829 of 25 June 2026 – website, 2.7.2026
Article 40 – (Deleted)
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 41 – Taxpayer rights
1. Taxpayers may:
a) in the prescribed manner, become familiar with information held by a tax authority about them;
b) represent their interests before a tax authority directly or through a representative;
c) not present any documents related to tax administration to any controlling or law-enforcement body (other than a tax
authority), unless such body has authority under this Code;
d) enjoy tax privileges;
e) obtain a refund for the sum of any overpaid tax and/or sanction (including a customs sanction), and/or keep it as a credit against
future tax liabilities;
f) request information about the grounds for exercising tax control over them;
g) provide appropriate explanations to a tax authority when subjected to a tax control;
h) attend tax field audits conducted in relation to them, receive from a tax authority original or certified copies of any decision
pertaining to them, and demand compliance with the legislation of Georgia during these activities;
i) appeal actions or decisions of a tax authority as provided by law;
j) not fulfil an illegal act issued or request made by a tax authority;
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k) demand reimbursement of damages incurred as a result of unlawful decisions or action of a tax authority;
l) enjoy any other rights under the legislation of Georgia.
2. Protection of taxpayer rights and legitimate interests shall be guaranteed in administrative and judicial proceedings.
3. Violation of taxpayer rights and legitimate interests shall carry liability as prescribed by law.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 42 – (Deleted)
Law of Georgia No 3613 of 28 May 2015 – website, 4.6.2015
Article 43 – Taxpayer obligations
1. Taxpayers shall:
a) fulfil tax liabilities in accordance with the tax legislation of Georgia;
b) be enrolled with a respective tax authority or register with the Register of Entrepreneurs and Non-entrepreneurial (Non-
commercial) Legal Entities and the Register of Citizens’ Political Alliances (Parties);
c) file tax returns, computations, and accounting documents with a tax authority as provided by the legislation of Georgia;
d) submit to a tax authority and its authorised person the documents (certificates) needed for computation and payment of taxes in
the case of a tax audit or in any other cases provided for by this Code;
e) comply with the lawful requests of a tax authority and authorised persons with respect to the elimination of detected violations
of tax legislation; not prevent authorised persons from fulfilling their official duties;
f) ensure the safekeeping of documents necessary for identifying a taxable object for three years. Such period shall be calculated
from the end of the calendar year of relevant tax period, for the identification of tax liabilities of which such documentation is
necessary.
g) place a copy of a taxpayer certificate and in the case of retail trade – price labels (in Georgian national currency) at a place
conspicuous for customers;
g1) not impede a person chosen by the Revenue Service under the legislation of Georgia in delivering services related to affixing
mandatory excise stamps/mandatory markings.
h) fulfil any other obligations provided for by the tax legislation of Georgia.
2. A Georgian enterprise, a Georgian organisation and an entrepreneur natural person shall submit to a tax authority, according to
the place of tax registration, information on opening bank accounts (other than deposit (time deposit) accounts) outside Georgia
within five business days after opening such accounts.
21. A financial institution of Georgia defined in the Agreement between the Government of the United States of America and the
Government of Georgia to Improve International Tax Compliance and to Implement the Foreign Account Tax Compliance Act
(FATCA) shall, within the framework of this Agreement, transfer to a tax authority the information provided for under the same
Agreement.
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3. A taxpayer shall submit to a tax authority the information set forth in the second paragraph of this article in the form approved
by the Minister of Finance of Georgia.
4. For non-fulfilment or improper fulfilment of the obligations provided for by the tax legislation of Georgia, a taxpayer shall be
liable as prescribed by this Code and/or other legislative acts of Georgia.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5557 of 20 December 2011 – website, 28.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016
Article 44 – Correspondence with taxpayers
1. A tax authority shall send and/or present a document to a person in writing or electronically.
2. A document sent in writing by a tax authority shall be signed by an authorised person. The addressee shall be given the original
or a certified copy of the document.
21. If upon the presentation of a written document to the address of persons defined under the sixth and seventh paragraphs of this
article or to the legal address defined in registration documents, the clerical office or the structural unit of the same function
refuses to accept a written document, the tax authority shall be entitled to use technical means for recording the refusal.
3. A tax authority shall decide on the form of sending and/or presenting a document.
4. If the same document is presented to a person several times or in several forms, the date of presenting such document shall be
the day on which the document was first delivered.
5. If upon the presentation of a written document a person refuses to accept it, the presenting person shall make an appropriate
note.
51. In the case provided for under the fifth paragraph of this article, if the fact of presenting a written document has been recorded
using technical means, such document shall be deemed accepted.
6. A written document shall be deemed to have been served on a natural person if the document is delivered to:
a) the addressee in person;
b) an authorised or legal representative of the person;
c) any adult family member residing with that person at his/her place of residence;
d) a clerical office or any structural unit of the same function at the place of business of an entrepreneur natural person;
e) a person directly performing the economic activity of a natural person, when there is an order of an authorised person on
execution of a tax offence report, current control procedures and/or tax enforcement measures.
7. A written document shall be deemed to have been served on a taxpayer (other than a natural person) if the document is
delivered to:
a) the authorised person;
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b) an authorised or legal representative of the person;
c) a clerical office or any structural unit of the same function at the legal address indicated in registration documents;
d) a person directly performing the economic activity of a taxpayer, provided there is an order of an authorised person on the
execution of a tax offence report, current control procedures and/or tax enforcement measures;
e) any adult person residing at the residential apartment indicated as a legal address in registration documents.
8. The delivery of a document shall be confirmed by the recipient’s signature on a copy of the document or on the relevant mail
document. The recipient’s full name and his/her relationship with the addressee, as well as the date of delivery of the document
shall be indicated next to it.
9. A document sent electronically by a tax authority to a person shall be deemed delivered as soon as the addressee reviews it, and
in the case provided for in Article 264(2) of this Code – as soon as the person reviews it or on the 30th day after it has been
posted on an authorised user’s page, unless the addressee reviewed the notice within that period.
10. A tax authority/a dispute resolution body or the National Bureau of Enforcement shall have the right to make a document
public if a taxpayer (except for a natural person) has not read the document sent by the tax authority in an electronic form within
30 days after it is posted on the authorised user’s webpage of the taxpayer. If a taxpayer is a natural person, a document can be
made public if the following conditions have been met:
a) the document has been sent/submitted to a person at least twice in a written form but it could not be served on the addressee;
b) the person is not an authorised user of the official webpage of the Revenue Service or the addressee has not read the document
within 30 days after it was posted on the authorised user’s webpage;
11. A document shall be published by posting it on the official website of the Ministry of Finance of Georgia or the National
Bureau of Enforcement and shall be deemed to have been delivered on the 20th day after such posting.
12. In exercising the rights defined in this Code, a tax authority may create, receive, send, keep and issue any electronic or written
document (including in archived form) that may have legal implications, and use an electronic document circulation system.
13. A taxpayer may present documents to a tax authority in writing or electronically.
14. A written document presented by a taxpayer to a tax authority shall be signed by an authorised person. The original document
or its certified copy shall be submitted to the addressee.
15. If a taxpayer sends a document to a tax authority by post, the date of its submission shall be the day when the document is sent.
At the same time, the term for responding to the document shall commence from the day following the day on which the mail is
actually delivered to a tax authority.
16. The procedure for electronic correspondence/public dissemination of documents between a taxpayer and a tax/dispute
resolution authority shall be determined by an order of the Minister of Finance of Georgia.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 649 of 21 April 2017 – website, 10.5.2017
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
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SECTION III
PROVIDING INFORMATION TO TAXPAYERS AND THE SYSTEM OF GEORGIAN TAX AUTHORITIES
Chapter V – Providing Information to Taxpayers
Article 45 – (Deleted)
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 46 – Clarifications on the application of the tax legislation of Georgia
A tax authority may send a written clarification to a person on the application of the tax legislation of Georgia. This clarification
shall be regarded as a recommendation.
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Article 461 – Public rulings
1. Based on a decision made by a dispute resolution authority or on the analysis of the current practice of taxation of taxpayers by a
tax authority, the Minister of Finance of Georgia may issue a public ruling on the application of certain provisions of the tax
legislation of Georgia.
2. A document shall be regarded as a public ruling if it states that it is a public ruling.
3. A public ruling (including a decision on modifying or cancelling a public ruling) shall be published on the official website of the
Legislative Herald of Georgia.
4. A public ruling shall enter into force from the date indicated in it and shall be valid for an indefinite term or for the period
stated in it. This ruling shall be binding for a tax authority from the day of its entry into force.
5. A public ruling shall not be applied if the provisions with respect to which the ruling was issued have been modified or
repealed.
6. The Minister of Finance may declare a public ruling, or its part, as invalid or modify it.
7. If a person acts according to a public ruling, a monitoring/law-enforcement authority may not adopt a decision contradicting the
ruling and may not impose additional taxes/sanctions.
8. If there is contradiction between two public rulings or between a public ruling and an advance tax ruling, the person concerned
may act according to one of the rulings at its discretion.
9. The procedure for issuing a public ruling shall be determined by the Minister of Finance of Georgia.
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Article 47 – Advance tax ruling
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1. The Revenue Service may, on the basis of a person’s application, issue an advance tax ruling according to a future or completed
transaction on:
a) the tax reporting rules provided for by this Code and Customs Code of Georgia and/or outstanding tax/customs liabilities;
b) the reporting rules and/or outstanding liabilities related to a fee administration of which is carried out by a tax authority.
2. An advance tax ruling shall be issued within not later than 90 days after submission of a request.
3. An advance tax ruling shall apply only to the persons to whom it has been issued. At the same time, an advance tax ruling shall
indicate the norm of the legislation of Georgia on which the ruling was based.
4. Different advance tax rulings may not be issued with respect to identical transactions performed by different persons.
5. If a person acts under an advance tax ruling, controlling/law-enforcement authorities may not make decisions contradicting the
advance tax ruling or impose any charges and/or sanctions.
6. An advance tax ruling shall not be applied if:
a) the facts and circumstances indicated in the advance tax ruling and which would have affected the advance tax ruling are
different from those actually existing;
b) the norm of the legislation of Georgia which formed the basis for the advance tax ruling has been repealed or amended.
7. A norm of the legislation of Georgia that is unfavourable to a taxpayer and has been given retroactive force may not affect a
transaction performed under an advance tax ruling issued prior to enactment of such norm.
8. (Deleted – 28.6.2019, No 4906).
9. The information provided by a person in a request for an advance tax ruling shall be treated as a tax secret.
10. If a person disagrees with an advance tax ruling of a tax authority, he/she may appeal it as provided in this Code.
11. An advance tax ruling shall need to be agreed upon with the Minister of Finance of Georgia.
12. At the request of a person and in the case of submission of additional or amended information, the Revenue Service may
amend its advance tax ruling, unless the person has already applied the advance tax ruling issued before such amendment, in
relation to the transaction on which the ruling was based.
13. The procedure for issuing an advance tax ruling shall be determined by order of the Minister of Finance of Georgia.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Chapter VI – Georgian Tax Authorities and their Main Functions
Article 48 – Georgian tax authorities
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1. Georgian tax authorities shall be the Revenues Service and its structural units as determined by the Minister of Finance of
Georgia.
2. The Revenue Service is a legal entity under public law within the Ministry of Finance of Georgia exercising public control. The
Revenue Service exercises its powers across the whole territory of Georgia and may have offices in one or several locations.
3. Georgian tax authorities shall exercise tax control in Georgia, except where such power is granted under this Code to another
authority.
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Chapter VII – Rights and Obligations of Tax Authorities
Article 49 – Rights of tax authorities
1. Under this Code, within the scope of their authority and in the manner provided for by the legislation of Georgia, tax
authorities may:
a) audit financial documents, books, accounts, cost estimates, funds, securities and other valuables, computations, declarations, and
other tax computation and payment documents;
b) obtain from taxpayers and/or their representatives tax computation and payment documents, as well as written and oral
explanations regarding issues arising in the course of tax audit;
c) examine production, storage, sales and other facilities of enterprises, organisations and entrepreneur natural persons, perform
tax monitoring, take inventory of stock of goods, conduct observations by time-study or any other method and determine the
number of taxable objects, conduct tax audits, monitor taxpayer observance of the rules for use of cash registers and, in the case of
non-compliance with this rule, determine and impose appropriate liabilities under the legislation of Georgia with respect to those
persons;
d) summon taxpayers to a tax authority (a taxpayer’s legal or authorised representative who has accounting documents and/or
information related to the taxation of the taxpayer may appear before a tax authority instead of the taxpayer);
e) independently determine the amount of tax liabilities of a taxpayer based on information held by the tax authority (including
information on the expenditures of a taxpayer) or by a comparison method – by analysing information of other similar taxpayers,
unless a taxpayer submits the accounting documents required for tax control or performs bookkeeping in violation of established
procedure, or in other cases provided for by this Code;
f) apply sanctions against taxpayers who have violated the tax legislation of Georgia;
g) for the enforcement of payment of tax arrears, apply the measures provided for by this Code against a taxpayer;
h) prepare administrative offence reports against offenders for tax legislation violations and adopt rulings on the imposition of
administrative sanctions;
i) perform a test purchase of goods/services from a taxpayer to fully determine an object of taxation;
j) hire specialists or experts for tax administration purposes;
k) obtain data, certificates, documents and other necessary information free of charge from the state and municipality bodies for
work-related purposes. Where necessary, the procedure for exchange of information between state bodies shall be determined by a
resolution of the Government of Georgia;
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l) request and obtain copies of accounting documents (a copy certified by the taxpayer, if necessary);
m) install readers and/or obtain their readings and seal documents and other materials in the manner provided for by this Code.
n) receive from a financial institution of Georgia defined in the Agreement between the Government of the United States of
America and the Government of Georgia to Improve International Tax Compliance and to Implement the Foreign Account Tax
Compliance Act (FATCA), within the framework of this Agreement, the information provided for under the same Agreement, and
transfer this information to a competent body of the United States of America defined under the Agreement.
2. Tax authorities shall also have the rights provided under this Code and other legislative acts.
3. Under an agreement between a tax authority and the National Bureau of Enforcement, in order to secure the payment of tax
arrears falling within the authority of a tax authority under the tax legislation of Georgia, the National Bureau of Enforcement
shall demand and obtain a list of assets from a taxpayer for the purpose of seizing a taxpayer’s property, take inventory of a
person’s property, evaluate the property, prepare an act for seizure of the property, seal the property, ensure registration of a
seizure of the taxpayer’s property with a registration authority, prepare a report on tax offences where so provided by this Code,
apply to a court on behalf of a tax authority with a request to sell property or directly transfer it to the State in cases where the
National Bureau of Enforcement seizes a person’s property, and perform other necessary actions for the purposes specified in this
paragraph.
4. Under an agreement between a tax authority and a legal person with approval of the Government of Georgia, certain types of
taxpayer services falling within the authority of a tax authority under the tax legislation of Georgia may be performed by such
legal person.
5. The approval of the Government of Georgia referred to in the fourth paragraph of this article shall not be required if the
agreement is made between a tax authority and the National Agency of Public Registry.
6. (Deleted – 1.5.2015, No 3581).
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 491 – General analytical procedures
1. A tax authority may perform general analytical procedures.
2. General analytical procedures shall mean collection and analysis of information about a person and, based on the analysis,
planning and optimisation of tax administration measures, including collection and analysis of information about a taxable entity,
and study of the reasons for the origination of tax liabilities and overpayments.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 50 – Personal tax advisor
1. To facilitate interaction with a tax authority in exercising rights and discharging obligations under this Code, a taxpayer may use
http://www.matsne.gov.ge 20000000005001016012
the services of a personal tax advisor.
2. A personal tax advisor shall be a tax authority employee who renders a service defined by an order of the Minister of Finance of
Georgia to a taxpayer. Service of a personal tax advisor shall not include determination of the amount of taxpayer’s tax liabilities.
3. Types of services to be rendered by a personal tax advisor to a taxpayer, the procedure and conditions for employing services
shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 51 – Obligations of tax authorities
1. Within the scope of their authority, tax authorities shall:
a) comply with the tax legislation of Georgia, act in accordance with the requirements of this Code and other acts of the tax
legislation of Georgia and participate in the implementation of national tax policy;
b) protect the rights of taxpayers and the interests of the state;
c) exercise control over the accuracy and completeness of tax computations and their timely payment, conduct tax audits as
provided for by this Code and, in the course of the audit, inform taxpayers of their rights and obligations;
d) ensure taxpayers’ timely registration;
e) account for taxes charged and paid to the budget and prepare reports on taxes paid;
f) refund overpaid amounts to a taxpayer as prescribed by this Code;
g) protect confidentiality of taxpayer information and observe rules for storing information in accordance with this Code;
h) design declaration forms and other tax computation and payment forms and ensure the provision of information to a taxpayer;
i) study, analyse and assess the violations of the tax legislation of Georgia and take appropriate measures to eliminate the causes of
or conditions for tax offences;
j) identify natural and legal persons who evade taxes; prevent tax offences, conduct tax offence cases and apply liability measures
as provided by this Code;
k) maintain a national register of cash register models permitted for cash settlements with customers, register cash registers, and
monitor the compliance with rules for operating cash registers;
l) receive applications, notifications and other information on violations of the tax legislation of Georgia and examine them as
provided by law;
m) consider letters, complaints and queries of taxpayers in the prescribed manner and, if necessary, inform them free of charge of
the applicable taxes, tax computation and payment rules, and of the rights and obligations of a taxpayer;
n) raise awareness about the application of the tax legislation of Georgia, issue methodological guidelines, manuals and brochures,
and publish advice on tax matters and explanations in the media;
o) conduct administrative proceedings on administrative offences as provided for by the Administrative Offences Code of Georgia;
p) deliver (send) tax audit reports, other decisions and notifications of tax authorities to a taxpayer in the manner and within the
timeframes provided for by this Code and other tax legislation of Georgia;
q) present a tax notice to a taxpayer, and in the case of its noncompliance or improper compliance, take actions under this Code to
ensure compliance;
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r) promptly confirm receipt of letters delivered personally by taxpayers and of other documents provided for by this Code.
s) ensure the tax registration of taxpayers (maintenance of a Register) according to this Code, and the assignment of identification
numbers (except for persons subject to registration with the Register of Entrepreneurs and Non-entrepreneurial (Non-commercial)
Legal Entities and the Register of Citizens’ Political Alliances (Parties)).
2. A tax authority shall, not later than 10 calendar days after receiving a taxpayer’s request, provide the taxpayer with a statement
showing changes to its tax liabilities and the status of the completion of those liabilities for the period specified in the request.
3. Tax authorities shall also fulfil the obligations provided for by this Code and other legislative acts.
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016
Article 52 – Delegation of authority
The head of a tax authority may grant specific authority to any employee. The employee may not transfer the authority delegated
to him/her to another person.
SECTION IV
TAX LIABILITY
Chapter VIII – Tax Liability and its Fulfilment
Article 53 – Tax liability and its fulfilment
1. Tax liability is the obligation of a taxpayer to pay taxes established by this Code, as well as taxes established by this Code and
introduced by a municipality representative body.
2. A person shall be obligated to pay taxes upon the occurrence of a taxable event as determined by the tax legislation of Georgia.
3. Tax liability shall be deemed fulfilled if the tax amount is paid within the set timeframe.
4. Tax liability shall be paid directly by a taxpayer, unless otherwise provided by the legislation of Georgia. A taxpayer’s tax
liability may be paid by another person in the manner prescribed by the National Bank of Georgia.
5. The procedure and/or timeframe for payment of tax liability may be changed in the cases as provided for by this Code.
6. The day of the payment of taxes shall be the day when the tax amount is transferred into the relevant account of the Budget,
unless otherwise provided by the tax legislation of Georgia.
7. (Deleted – 1.5.2015, No 3581).
8. Under the Law of Georgia on Oil and Gas, based on the application of the parties to the Production Sharing Agreement and at
the decision of the Minister of Finance of Georgia, payment of tax liabilities may be imposed on the party receiving a profit from
the state-owned share of oil and gas.
9. With regard to import payments, tax liabilities shall be considered discharged in cases provided for by Article 62(2)(a-d) of the
Customs Code of Georgia.
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 54 – Obligations of banking institutions with regard to the payment of taxpayer tax liabilities
1. A banking institution shall, first of all, fulfil a taxpayer’s payment order for the payment of taxes and a tax authority’s collection
order for debiting funds from the bank account in the following order of precedence:
a) a tax authority’s collection order:
b) a taxpayer’s payment order.
11. The obligation of a banking institution specified in the first paragraph of this article shall not restrict a person’s right to use
funds exceeding the uncollected amount of the collection order until the full payment or after partial payment of the collection
order.
2. If there are funds in a person’s bank account, the banking institution shall fulfil a payment order or a collection order not later
than the banking day following the day of receipt of the order, unless otherwise provided for by this Code. A taxpayer shall bear
the cost of services related to the collection order.
3. If the amount on a person’s bank account is not sufficient to fulfil a payment order or a collection order, they shall be paid not
later than the banking day following the day when funds are transferred into the account.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 55 – Payment of tax liabilities in the case of liquidation of an enterprise/organisation (including in the case of registration
of commencement of the process of winding up)
1. If an enterprise/organisation is liquidated (including if the commencement of the process of winding up is registered), the
requirements/liabilities provided for by the tax legislation of Georgia shall be fulfilled and the tax arrears shall be paid by the
enterprise/organisation, unless otherwise provided for by this article.
2. If an enterprise provided for by Article 21(1)(c) of this Code is liquidated/terminates its activities (if its tax registration is
cancelled), the partners/participants of the aforementioned enterprise shall fulfil tax liabilities and pay tax arrears jointly and
severally.
3. If an enterprise/organisation is liquidated (including if the commencement of the process of winding up is registered), a tax
authority shall refund any overpaid amount to the aforementioned enterprise/organisation under the procedure established by this
Code.
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 56 – Payment of tax liability in the case of reorganisation of an enterprise/organisation
1. Tax liability and tax arrears of a reorganised enterprise/organisation shall be paid by its legal successor as provided by this Code.
2. In the case of a merger of several enterprises/organisations, the enterprise/organisation formed as a result of the merger shall be
the legal successor with respect to payment of tax liabilities of these enterprises/organisations.
http://www.matsne.gov.ge 20000000005001016012
3. If one enterprise/organisation is acquired by another, the legal successor with regard to payment of tax liabilities/arrears of the
acquired enterprise/organisation shall be the acquiring enterprise/organisation.
4. If an enterprise/organisation is split into several enterprises/organisations, the enterprises/organisations created as result of the
split shall be legal successors with respect to payment of tax liabilities/arrears of the original enterprise/organisation.
5. If there are several legal successors, the share of each of them with respect to payment of tax liabilities/arrears of the reorganised
enterprise/organisation shall be determined under the division balance sheet or other deed of transfer. Newly formed
enterprises/organisations shall be jointly and severally responsible for payment of tax liability/arrears of the reorganised
enterprise/organisation or its respective part.
6. If an enterprise/organisation changes its organisational and legal form, the enterprise/organisation arising from such
reorganisation shall be the legal successor with regard to payment of tax liability/arrears of the original enterprise/organisation.
7. If one or several enterprises/organisations separate from an enterprise/organisation, the separated enterprise(s)/organisation(s)
shall be subject to paragraphs 4 and 5 of this article.
8. Any overpaid amount paid before the reorganisation of an enterprise/organisation shall be credited by a tax authority against
future tax liabilities of the legal successor of the reorganised enterprise/organisation pro rata to the total amount or refunded to the
legal successor(s) (pro rata to their shares) as provided by this Code.
Article 57 – Payment of tax liabilities of a deceased person
1. Tax arrears of a deceased person shall be paid by his/her heirs pro rata to their shares in the inheritance, from the day of receipt
of an inheritance certificate.
2. Tax arrears of a deceased person shall be the tax arrears as of the day of his/her death.
3. The heir to the deceased person shall notify a tax authority of having obtained an inheritance certificate if he/she is aware of the
tax arrears of the deceased person.
4. A tax authority shall send a notice of the tax arrears not later than 30 days after it becomes aware that the person obtained an
inheritance certificate.
5. Tax arrears of a deceased person shall be written off, if:
a) the deceased person has no heir;
b) the heir waives the inheritance;
c) the amount of the tax arrears of the deceased person exceeds the value of the inherited property – in the amount of the
outstanding amount of tax arrears.
6. An heir who continues the economic activity of the deceased person shall:
a) notify a tax authority accordingly;
b) before starting the economic activity, become registered as a taxpayer, and if the deceased person was a VAT payer, become
registered as a VAT payer;
c) pay tax arrears of the deceased person;
d) fulfil a taxpayer’s other obligations under this Code.
7. An heir who continues the economic activity of the deceased person may:
a) apply for a refund for the sum of any tax and/or sanction (including a customs sanction) overpaid by the deceased person or
keeping it as a credit against future taxes;
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b) use the deceased person’s tax source documents for tax reporting;
c) present tax returns (including, adjusted ones) for the period of the deceased person’s activity;
d) where so provided by this Code, use appropriate documents of the deceased person to confirm the costs deductible from total
revenue and to obtain a deduction of excise tax/VAT;
e) continue a tax dispute started by the deceased person;
f) exercise a taxpayer’s other rights under this Code.
8. A tax authority shall unite the deceased person’s and his/her heir’s personal account cards if the heir carries on with the
economic activity of the deceased person.
9. If an heir applies for a refund for the sum of any tax and/or sanction (including a customs sanction) overpaid by the deceased
person or keeping it as a credit against future taxes, a tax authority shall, not later than three months after the taxpayer’s
application is lodged:
a) transfer the sum of any tax and/or sanction (including a customs sanction) overpaid by the deceased person to the heir’s personal
account card;
b) be authorised to establish compliance of the overpaid sum of a tax and/or sanction on a person’s personal account card with the
legislation of Georgia, including through a tax inspection;
c) in the case any outstanding tax liability of the deceased person is identified, be authorised to impose a respective tax:
c.a) to the heir’s personal account card if the heir carries on with the economic activity of the deceased person;
c.b) to the heir’s personal account card, within the scope of the overpaid sum of a tax and/or sanction if the heir does not carry on
with the economic activity of the deceased person;
d) after the procedures provided for in subparagraphs (a)-(c) of this paragraph are performed, refund to the heir of the deceased
person, under the procedure established by the legislation of Georgia, the sum of any tax and/or sanction overpaid by the deceased
person, or keep it as a credit against future tax liabilities.
10. In the case provided for in paragraph 9(c) of this article, sanctions defined by this Code shall not apply to the heir.
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 58 – Payment of tax liabilities of missing persons and beneficiaries of support
1. Tax arrears of a natural person who has been declared missing by a court shall be paid within three months after the person is
declared missing, at the expense of the property of the missing person, by the person who is authorised by guardianship authorities
to manage the property of the missing person.
2. A tax authority shall send to the person who is authorised by guardianship authorities to manage the property of the missing
person a notice requesting payment of the missing person’s tax arrears.
3. Tax liabilities of a beneficiary of support shall be paid by his/her supporter at the expense of the property of the beneficiary of
support, unless otherwise determined under the court decision. Tax arrears of a beneficiary of support shall be paid by his/her
supporter at the expense of the property of the beneficiary of support, unless otherwise determined under the court decision.
4. Tax arrears of a person recognised as missing or declared as a beneficiary of support by court shall be regarded as bad debt and
shall be written off if his/her property is insufficient to cover the tax arrears and unless otherwise determined under court decision
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with respect to the beneficiary of support.
5. The written-off tax arrears shall be restored the day the decision is made to reverse the court’s recognition of a person as missing
or declaration as a beneficiary of support.
6. Tax arrears of a missing person or a beneficiary of support shall be the tax arrears as of the date when he/she was recognised as
missing or declared as a beneficiary of support by court.
Law of Georgia No 3349 of 20 March 2015 – website, 31.3.2015
Article 59 – Tax period
1. Tax period shall be the period according to which a taxpayer’s tax liability is determined in relation to a specific tax.
2. If an enterprise/organisation is founded (becomes publicly registered) after the beginning of a calendar year before 1 December
of that year, its first tax period shall be the period from its foundation(registration) up to the end of that year. At the same time,
the day of foundation of the enterprise/organisation indicated in Article 21(1)(c) of this Code shall be the day on which a joint
activities agreement is signed.
3. If an enterprise/organisation is founded from 1 December through 31 December, its first tax period shall be the period from the
day of foundation up to the end of the next year, unless otherwise provided by this article.
4. If an enterprise/organisation is liquidated/reorganised before the end of a calendar year, its last tax period shall be the period
from the beginning of the year up to the day when its liquidation/reorganisation ends.
5. If an enterprise/organisation is founded after 30 November of the year preceding the year of its liquidation/reorganisation, its
first and last tax periods shall be the period from the date of foundation up to the day on which its liquidation/reorganisation is
finished.
6. The rules provided for in the fourth and fifth paragraphs of this article shall not apply to enterprises/organisations from which
one or several enterprises/organisations separated or which acquired one or several enterprises/organisations.
7. If during a tax period, a Georgian enterprise/organisation acquires the status of a foreign enterprise or a foreign enterprise
acquires the status of a Georgian enterprise, the tax period shall be divided into two parts: in the first part the
enterprise/organisation shall pay taxes according to its original status, and in the second part it shall pay taxes according to the
acquired status.
71. (Deleted – 26.12.2013, No 1886).
8. The rules provided by paragraphs 2 through 4 of this article shall not apply to taxes, the tax period of which is not a calendar
year.
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 60 – Tax privileges
1. Exemption from the national or local taxes provided for by this Code may be granted only by making amendments to this Code.
2. Tax privilege shall be any advantage given to a certain category of taxpayers over other taxpayers, namely, the possibility to pay
less tax or be tax exempt.
3. A tax privilege in relation to a local tax shall be granted by making amendments to the relevant normative act.
4. No individual tax privileges may be granted or individual tax exemptions made.
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5. A taxpayer may enjoy tax privileges from the moment when the relevant legal basis for the privileges arise, throughout the
entire period of their validity.
Article 61 – Tax assessment
1. Tax assessment shall mean computing by a tax authority of the tax amount payable by a taxpayer for a specific tax period and
recording it in a taxpayer’s personal account card. The procedure for maintaining the card shall be determined by the Minister of
Finance of Georgia.
2. Tax may be assessed based on:
a) a tax return/customs declaration;
a1) (Deleted – 1.5.2015, No 3581);
b) information on the amounts paid under Article 154 of this Code;
c) a tax audit report;
d) information on a person’s tax liability provided to a tax authority by other controlling or law-enforcement authorities;
e) information (data) communicated to a tax authority by the National Agency of Public Registry, another registration body, and
by a municipality body for the assessment of property tax on land;
f) information on assessing VAT on the sale of goods in the case provided for by Article 1611 of this Code;
g) information identified during tax/customs proceedings.
3. If a person does not present the information needed for assessment of taxes, a tax authority may charge taxes based on
information available to it.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 62 – Tax payment timeframes
1. The timeframe for payment of taxes, including current tax payments, shall be set according to each tax.
2. If a tax payment timeframe is not specified by this Code, it shall be paid within the timeframe set for filing tax returns, and in
other cases, within 30 days after receiving a tax notice.
3. The import payments payable under a customs declaration shall be paid within the time limit set for the payment of import
payments under the Customs Code of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
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Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 63 – Refunding overpaid amounts
1. If the amount of taxes and/or sanctions (including a customs sanction) paid by a taxpayer exceeds the amount of the assessed
taxes and/or sanctions (including a customs sanction), the tax authority shall, on the basis of the taxpayer’s request, refund the
overpaid sum to the taxpayer not later than one month after the request is submitted.
2. If the amount of taxes and/or sanctions (including a customs sanction) paid by a taxpayer exceeds the amount of the
acknowledged tax arrears, the tax authority shall use the overpaid sum to cover the tax arrears that will be charged and
acknowledged in future.
3. (Deleted – 1.5.2015, No 3581).
4. (Deleted – 1.5.2015, No 3581).
5. (Deleted – 14.7.2020, No 6817).
51. (Deleted – 12.6.2012, No 6446).
6. (Deleted – 14.7.2020, No 6817).
7. The overpaid amount resulting from an incorrect debiting of the sum of a tax and/or tax sanction (including a customs sanction)
from a taxpayer’s bank account under a tax authority collection order, or from concurrent payment of a tax authority collection
order by two or more banking institutions, shall be refunded to the taxpayer not later than 15 days after filing an application with
the tax authority.
8. The procedure for refunding the overpaid sum to a taxpayer shall be established by the Minister of Finance of Georgia.
9. In an individual case, an overpaid amount may be refunded automatically to taxpayers who file electronic tax returns. The terms
and conditions for automatically refunding overpaid amounts shall be determined by the Minister of Finance of Georgia.
10. In individual cases, by decision of the head of the Revenue Service, the overpaid sum of a tax and/or sanction (including a
customs sanction) may be refunded to the taxpayer without submission of the taxpayer’s application for a refund. Cases of,
procedure and conditions for refunding the overpaid sum of a tax and/or sanction (including a customs sanction) without
submitting a taxpayer’s application for a refund shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5791 of 13 March 2012 – website, 23.3.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 64 – Tax notice
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1. A tax notice is an individual administrative-legal act of a tax authority that must be complied with as provided for in this Code.
2. A tax authority shall present a tax notice to a taxpayer if there is one of the following grounds:
a) assessment of tax, the computation of which is the obligation of a tax authority;
b) the decision of a tax authority on assessing tax and/or imposing a sanction or a tax offence report;
c) the decision on serving a notice of levy on a third person under Article 240(1) of this Code;
d) the decision of a customs authority on assessing the import payment and/or imposing a customs sanction on a person, or a
customs offence report.
3. (Deleted – 5.4.2023, No 2768).
4. A tax notice shall be deemed fulfilled from the moment the person pays the amount indicated in the tax notice.
5. The procedure for issuing tax notices shall be determined by order of the Minister of Finance of Georgia.
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 65 – Taxpayer's claim
1. A taxpayer's claim is a claim filed by a person with a tax authority for refunding the sum of overpaid taxes and/or sanctions
(including a customs sanction), which a tax authority has to fulfil in the cases provided for and under the procedure established by
this Code.
2. The basis for filing a taxpayer's claim shall be the overpaid sum of taxes and/or sanctions (including a customs sanction).
3. A taxpayer's claim shall be deemed fulfilled upon payment of the amount claimed.
4. If a tax authority deems that a taxpayer's claim is groundless, it shall submit a substantiated counterclaim to the taxpayer within
20 days after receiving the taxpayer's claim.
5. The person may appeal the tax authority’s counterclaim as provided in this Code.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 66 – Registration as a taxpayer
1. A Georgian citizen natural person, a person having a neutral ID or a neutral travel document, and persons legally residing in the
Autonomous Republic of Abkhazia and in Tskhinvali region (former Autonomous Region of South Ossetia) that are registered
under the procedure established by the legislation of Georgia and that are granted the personal number, except for a person whose
income is withheld at source or who is tax exempt, shall apply to a tax authority for granting the identification number to them
before starting economic activities.
2. Tax registration of taxpayers shall be carried out by the tax authorities under the procedure established by the Minister of
Finance of Georgia. This procedure shall not apply to persons whose registration under the legislation of Georgia is performed by
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the Legal Entity under Public Law operating under the Ministry of Justice of Georgia – the National Agency of Public Registry.
The procedure and conditions for assigning the identification number to these persons shall be defined by an order of the Minister
of Justice of Georgia.
3. A branch of a foreign enterprise that is subject to registration with the Register of Entrepreneurs and Non-entrepreneurial
(Non-commercial) Legal Entities shall be registered for tax purposes and issued an identification number by the National Agency
of Public Registry at the moment of the registration of the branch. At the same time, if the said foreign enterprise was registered
for tax purposes before the registration of the branch and was issued an identification number by a tax authority or if two or more
branches have been registered, the identification number first issued shall remain intact.
4. If the obligation to pay taxes and/or file tax returns arises in Georgia, a Georgian citizen natural persons, a person having a
neutral ID or a neutral travel document, and persons legally residing in the Autonomous Republic of Abkhazia and in Tskhinvali
region (former Autonomous Region of South Ossetia) that are registered under the procedure established by the legislation of
Georgia and that are granted the personal number (except for an entrepreneur natural person) may indicate, even without
completing tax registration procedures with a tax authority, their personal number indicated in their identity card, neutral ID card
or in a neutral travel document of a citizen, and the number granted to them at registration (identification number), when filing a
return in respect of the incurred tax, including customs liabilities and when paying taxes at a banking institution. Tax registration
of a Georgian citizen natural person, a person having a neutral ID card or a neutral travel document, and of persons legally
residing in the Autonomous Republic of Abkhazia and in Tskhinvali region (former Autonomous Region of South Ossetia) that are
registered under the procedure established by the legislation of Georgia and that are granted the personal number, shall be
conducted based on the details of their tax returns, customs declarations/re-export declarations and/or payment orders presented
to the banking institution, which evidence the payment of taxes.
5. A Georgian citizen natural person (including an entrepreneur natural person) shall be granted the personal number indicated in
his/her ID card as the identification number; a person having a neutral ID card or a neutral travel document shall be granted the
personal number indicated in the ID card/travel document, and a person legally residing in the Autonomous Republic of Abkhazia
and in Tskhinvali region (former Autonomous Region of South Ossetia) shall be granted the personal number granted to him/her
at registration.
6. The identification number of a natural person who is not a Georgian citizen shall be the 9-digit identification number issued by
the authority as determined under the legislation of Georgia.
7. An identification number shall be permanent and may not be changed or repeated, unless otherwise provided by the legislation
of Georgia.
8. Tax registration of an enterprise/organisation, an entrepreneurial entity and a non-entrepreneurial (non-commercial) legal
entity shall be performed according to the legal address; tax registration of a natural person shall be performed according to his/her
declared place of residence/business.
9. A taxpayer shall indicate its taxpayer identification number in a tax return, in correspondence with a tax authority and in any
other documents as determined by the tax legislation of Georgia.
10. In detecting a tax offence specified in Article 273 of this Code, a tax authority shall ensure the person’s tax registration as
prescribed by the Minister of Finance of Georgia.
Law of Georgia No 4998 of 1 July 2011 – website, 15.7.2011
Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016
Law of Georgia No 2476 of 6 June 2018 – website, 21.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 661 – Estimated assessment
1. A tax authority may, without a tax audit, conduct an estimated assessment on the basis of information it holds if:
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a) there is a reasonable belief that the amount of tax has been unreasonably reduced on a taxpayer’s personal account card. In this
case, an estimated assessment may be conducted only in the sum of the tax amount reduced;
b) a taxpayer has failed to fulfil the obligation to submit a tax return/calculation within the period set by the tax legislation of
Georgia.
2. An estimated assessment may be annulled by an adjusted assessment.
3. The estimated and adjusted assessment procedure shall be defined by an order of the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Chapter IX – Tax Reporting
Article 67 – Tax return
1. A tax return is a person’s statement used to assess his/her tax liabilities under this Code.
2. The amount of total tax liabilities in a tax return is computed in full laris. For this purpose, any tax liability under GEL 1 shall be
zeroed.
3. A person may file his/her tax return with a tax authority in person, or may send it by registered mail or electronically.
4. Except as defined by the Minister of Finance of Georgia, if a person fails to file a tax return he/she is deemed to have filed a tax
return, based upon which the amount of the assessed taxes equals zero. A tax return filed later for the given reporting period shall
be deemed as late filing.
5. Tax return forms and the procedure for their completion and electronic filing shall be determined by the Minister of Finance of
Georgia.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 68 – Extending deadlines for filing tax returns
The deadline for filing annual income, profit or property tax returns shall be extended for three months if a person has paid the
current taxes for the period subject to declaration (or has no obligation to pay current taxes) and applies in writing to a tax
authority for an extension of the deadline before the filing deadline expires. An extension of the deadline for filing tax returns
shall not affect the deadline for tax payment.
Article 69 – Making amendments to tax returns
1. If in a filed tax return a person discovers a mistake that causes a change in the tax liability, he/she shall make relevant
amendments to the tax return.
2. If an amended tax return is filed with a tax authority before its filing deadline expires, the amended tax return shall be deemed
as originally filed.
3. If a person files a tax return (including an amended tax return) for the period or issue, in respect of which a tax authority has
already conducted a tax audit or assessment, the tax authority may perform a calculation according to such tax return (including
an amended tax return). In this respect, the authorised person of the tax authority shall issue a reasoned order.
4. A person may not file a tax return (including an amended tax return) for the period or issue in respect of which a tax audit is
being conducted or is to be conducted, from the moment of service of the relevant order/notice of a judicial/tax authority on
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conducting a tax audit, or from posting of this order/notice electronically on a tax payer’s authorised user web page, or from
preparation of a tax offence report up to the service of the relevant tax notice to the person in question.
5. The restriction under the fourth paragraph of this article shall not apply if a tax notice is deemed invalid under Article 264(3) of
this Code.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Article 70 – Right to request information
1. A tax authority may request persons:
a) to provide accounting documents and/or taxation-related information (including information requested by another state’s
competent (authorised) body on the basis of an international agreement to which Georgia is a part);
b) to submit a list of their property.
2. In the cases provided by this Code, an authorised person of the National Bureau of Enforcement may exercise the right under
paragraph 1(b) of this article.
3. A tax authority may, during a tax audit (within the scope of this audit) of a taxpayer or upon application of another state’s
competent (authorised) body in accordance with an international agreement of Georgia, request confidential information on a
person, as provided for by Article 17 of the Law of Georgia on Commercial Bank Activities or Article 24 of the Law of Georgia on
Microbank Activities, from a banking institution. The tax authority shall request this information on the basis of a court decision
under the procedure established by the Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this
article and Article 702(1) and (3) of this Code.
31. A tax authority may request from a financial institution of Georgia defined in the Agreement between the Government of the
United States of America and the Government of Georgia to Improve International Tax Compliance and to Implement the Foreign
Account Tax Compliance Act (FATCA), within the framework of this Agreement, the information provided for under the same
Agreement, and transfer this information to a competent body of the United States of America defined under the Agreement.
32. A tax authority may, during a tax audit (within the scope of this audit) of a taxpayer or upon application of another state’s
competent (authorised) body in accordance with an international agreement of Georgia, request confidential information of a
person, as provided for by Article 43 of the Law of Georgia on Payment Systems and Payment Services, from a payment service
provider. The tax authority shall request this information on the basis of a court decision under the procedure established by the
Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this article and Article 702(1) and (3) of
this Code.
33. A tax authority may, during a tax audit (within the scope of this audit) of a taxpayer or upon application of another state’s
competent (authorised) body in accordance with an international agreement of Georgia, request confidential information of a
person, as provided for by Article 32(2) of the Law of Georgia on Securities Market, from a brokerage company, a licensed central
depositary, and a securities registrar. The tax authority shall request this information on the basis of a court decision under the
procedure established by the Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this article
and Article 702(1) and (3) of this Code.
34. A tax authority may, during a tax audit of a taxpayer conducted within the scope of this audit or upon application of another
state’s competent (authorised) body in accordance with an international agreement of Georgia, request confidential information of
a person, as provided for by Article 12(5) of the Law of Georgia on Investment Funds, from an asset management company and an
investment company. The tax authority shall request this information on the basis of a court decision under the procedure
established by the Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this article and Article 702
(1) and (3) of this Code.
5
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3 . A tax authority may, during a tax audit of a taxpayer conducted within the scope of this audit or upon application of another
state’s competent (authorised) body in accordance with an international agreement of Georgia, request confidential information of
a person, as provided for by Article 10 of the Law of Georgia on Microfinance Organisations, from a microfinance organisation.
The tax authority shall request this information on the basis of a court decision under the procedure established by the
Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this article and Article 702(1) and (3) of
this Code.
36. A tax authority shall be authorised, during a tax audit (within the scope of this audit) of a taxpayer or upon application of
another state’s competent (authorised) body in accordance with an international agreement of Georgia, to request confidential
information of a person, as provided for by Articles 502 and 522 of the Law of Georgia on the National Bank of Georgia, from a
loan provider and a currency exchange office. The tax authority shall request this information on the basis of a court decision
under the procedure established by the Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this
article.
[37. A tax authority shall be authorised, during a tax audit (within the scope of this audit) of a taxpayer or upon application of
another state’s competent (authorised) body in accordance with an international agreement of Georgia, to request confidential
information of a person, as provided for by Article 528 of the Law of Georgia on the National Bank of Georgia, from a factoring
company and a factoring platform. The tax authority shall request this information on the basis of a court decision under the
procedure established by the Administrative Procedure Code of Georgia, except as provided for by paragraph 31 of this article.
(Shall become effective from 1 January 2027)]
4. A tax authority shall not be authorised to transfer the information provided for by paragraphs 3 and 32-36 of this article to
persons provided for by Article 39(2) of this Code, except when the information is transferred to another state’s competent
(authorised) body under an international agreement of Georgia.
[4. A tax authority shall not be authorised to transfer the information provided for by paragraphs 3 and 32-37 of this article to
persons defined by Article 39(2) of this Code, except when the information is transferred to another state’s competent (authorised)
body under an international agreement of Georgia. (Shall become effective from 1 January 2027)]
5. A person shall accurately and fully provide the requested information to a tax authority/the National Bureau of Enforcement
within the period specified. A person, whose property has been seized by a tax authority, shall, if he/she has purchased new
property, adjust the submitted list of property not later than seven working days from purchasing the new property.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015
Law of Georgia No 1808 of 9 September 2022 – website, 23.9.2022
Law of Georgia No 2138 of 30 November 2022 – website, 15.12.2022
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 1456 of 1 April 2026 – website, 6.4.2026
Article 701 – Statement of a multinational enterprise group
1. A final parent company of a multinational enterprise group, which is a Georgian resident, shall submit a report by countries to a
tax authority not later than 12 months after the end of the accounting year.
2. A Georgian resident enterprise – a part of a multinational enterprises group – which is a final parent or surrogate parent
establishment, shall inform a tax authority thereof before end of the accounting year.
3. For the purposes of this article:
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a) a multinational enterprise group shall be any group which:
a.a) includes two or more than two enterprises that are tax residents of different countries/jurisdictions, or includes an enterprise
which is a resident of one country for taxation purposes and is subject to taxation in another country/jurisdiction, in relation to an
economic activity performed through its permanent establishment;
a.b) is not an exceptional multinational enterprise group;
b) an exceptional multinational enterprise group – in relation to any fiscal year of the group, a group whose overall consolidated
group revenues are less than EURO 750 000 000 during the fiscal year immediately preceding the accounting fiscal year, as it has
been included in its consolidated financial statement for this previous financial year;
c) a final parent enterprise – a part of a multinational enterprise group, which meets the following requirements:
c.a) directly or indirectly holds sufficient number of shares in one or more than one enterprise – part of such multinational
enterprise group that it is assigned to prepare consolidated financial statements in compliance with the accounting principles
generally effective in a country/jurisdiction of which it is a tax resident, or would be obligated to prepare them in the case of
trading at a public stock exchange with its shares;
c.b) there is no other enterprise – part of such multinational enterprise group, which directly or indirectly holds shares provided
for in subparagraph c.a) of this paragraph in the aforementioned enterprise – part of the multinational enterprise group;
d) a surrogate parent establishment – an establishment – part of a multinational enterprise group, which has been appointed by
this multinational enterprise group in a country/jurisdiction, of which it is a resident, as a sole substitute for a final parent
establishment for the purpose of submitting a statement by countries, when conditions under the order of the Minister of Finance
of Georgia have been met;
e) the following shall be deemed an enterprise – part of a multinational enterprise group:
e.a) any separate economic unit of a multinational enterprise group, which is included in the consolidated financial statements of
the multinational enterprise group for financial reporting purposes, or would be included therein in the case of trading at a public
stock exchange with shares of such economic unit of the multinational enterprise group;
e.b) any separate economic unit that is not included in the consolidated financial statements of the multinational enterprise group
only on the basis of size or materiality;
e.c) any permanent establishment of any separate economic unit of a multinational enterprise group under subparagraphs e.a) and
e.b), provided that the economic unit prepares a separate financial statement for the permanent establishment for financial/tax
reporting, and internal management control purposes.
4. The procedure for submitting a statement of a multinational enterprise group shall be defined by an order of the Minister of
Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 702 – Commitments provided for by the Multilateral Competent Authority Agreement on Automatic Exchange of
Financial Account Information (CRS MCAA) within the scope of the Convention of 25 January 1988 on Mutual Administrative
Assistance in Tax Matters, or the Agreement on Automatic Exchange of Financial Account Information between Georgia and the
appropriate jurisdiction
1. Reporting Financial Institutions (the ‘Reporting Financial Institution’) defined by the Multilateral Competent Authority
Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) within the scope of the Convention of 25
January 1988 on Mutual Administrative Assistance in Tax Matters, and/or the Agreement on Automatic Exchange of Financial
Account Information between Georgia and the relevant Jurisdiction (the ‘Agreements on Automatic Exchange of Information’)
shall carry out relevant procedures under the Common Reporting Standard provided for by the aforementioned Agreements, and
shall report to tax authorities on each reportable financial account of a resident in the relevant Jurisdiction.
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2. Information provided for by paragraph 1 of this article shall be reported to the tax authority after the end of a calendar year it is
related to, but not later than 30 June of the following calendar year.
3. The tax authority shall be entitled, in order to verify the information received under paragraph 1 of this article, to require that
the reporting financial institution submit additional information, for which purpose the tax authority shall set a reasonable period
of time for it of at least 15 calendar days.
4. The tax authority shall be entitled to forward the information received to the competent authorities of the Jurisdictions parties
to the Agreements on Automatic Exchange of Information, in which the aforementioned Agreements are effective.
5. The reporting procedure provided for by the Agreements on Automatic Exchange of Information shall be approved by the
Minister of Finance of Georgia.
6. The tax authority shall be entitled to exercise control of the fulfilment by the Reporting Financial Institution of the
requirements established under the Agreements on Automatic Exchange of Information, under the procedure established by the
Minister of Finance of Georgia.
7. Any transaction concluded or any act carried out by a person to evade the commitment under the Common Reporting Standard
provided for by the Agreements on Automatic Exchange of Information shall not release him/her/it from fulfilment of the
obligation defined by this article.
Law of Georgia No 2138 of 30 November 2022 – website, 15.12.2022
Article 71 – Obligations of banking institutions
1. A banking institution shall:
a) open a bank account for an entrepreneur natural person and/or enterprise/organisation based on documents evidencing the
granting of a taxpayer identification number, except as provided by subparagraph (b) of this paragraph;
b) notify the Revenue Service of the opening of a bank account for a foreign enterprise for the first time or closing the last account
of such enterprise, within three business days (except as provided by subparagraph (e) of this paragraph) and not perform any
debit transactions from the account until the Revenue Service receives the notification. Furthermore, based on the information
provided by a foreign enterprise, it shall provide the Revenue Service with the identification number of the foreign enterprise
and/or the actual address of a permanent establishment (if such information is available or if the person opening the account has
provided such information to the banking institution);
c) notify the relevant tax authority within three business days after the opening of an account for the first time or closing the last
account of the persons indicated in subparagraph (a) of this paragraph and not perform any debit transactions from the account of
the person indicated in subparagraph (a) of this paragraph within two business days after receipt of such information by the tax
authority, except where a debit transaction is related to payment of taxes to the budget. If the Revenue Service and the banking
institution have signed an agreement on electronic exchange of information (including collection orders), the timeframes
indicated in this subparagraph shall be determined under the agreement, but they shall not exceed the timeframes provided for in
this subparagraph;
c1) within three days after establishing the fact that a natural person is an entrepreneur natural person, notify a tax authority the
date of the opening of the first active account and the date of closing the last account of that person. If the Revenue Service and
the banking institution have concluded an agreement on electronic exchange of information (including collection orders), the
timeframe indicated in this subparagraph shall be determined under the agreement, but it shall not exceed the timeframe set in
this subparagraph.
d) not perform any debit transactions (except for the bank institution service charges, unless such transactions are related to the
payment transactions outside the system of the banking institution) from the account of the persons referred to in subparagraph
(a) of this paragraph without indicating the taxpayer’s identification number;
e) notify the Revenues Service, in the cases and according to the timeframes and conditions specified in the agreement concluded
with it, about the opening and/or closing of the accounts only of the persons referred to in subparagraphs (a) and (b) of this
paragraph and apply collection orders or seizure orders issued by a tax authority with the indication of the identification numbers
of such persons, to the account(s) of such persons within the scope of the collection or seizure order, which shall not restrict the
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right to administer those funds that are in excess of the collection or seizure order, and if the funds on the bank account(s) are not
enough to fully fulfil the collection or seizure order, automatically apply the collection or seizure order to all of their bank
accounts;
f) at the request of the Revenue Service, provide it with information regarding the opening or closing of a taxpayer’s account not
later than three business days after such request. The Revenue Service may request such information within the timeframe
provided in this Code. The timeframe shall commence from the opening/closing of an account. In other cases, information may be
requested under a court decision. If the Revenue Service and a banking institution have signed an agreement on electronic
exchange of information, the information specified in this subparagraph may be requested electronically. In that case, the
timeframe indicated in this subparagraph shall be determined under the agreement;
g) inform the person about the registration for payment of a collection order issued by a tax authority with respect to the person’s
bank accounts, except where it is impossible to inform the person.
h) transfer, within the framework of the Agreement between the Government of the United States of America and the
Government of Georgia to Improve International Tax Compliance and to Implement the Foreign Account Tax Compliance Act
(FATCA), to a tax authority the information provided for under this Agreement.
2. If the information provided for in paragraph 1 of this article is communicated by way of delivering a written notice to a tax
authority, it shall be certified by the signature of an authorised person of the tax authority on a second copy of the notice of
opening a bank account, and where the notice submitted to the tax authority is not certified within two business days, it shall
automatically be considered as being certified; consequently, the banking institution shall have the right to perform debit
transactions from that account. In addition, the notice shall be considered as being delivered when the correspondence is received
by the tax authority.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 4458 of 28 October 2015 – website, 11.11.2015
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 72 – Tax source document
1. A tax source document shall be a written document based on which the parties to a business transaction can be identified. It has
a date and includes the list and value of the supplied goods/rendered services. The value of goods (including a unit price of goods)
need not be indicated in a tax source document issued for a transaction on the exchange of goods/services (barter transaction).
2. A tax source document shall be made in at least two identical copies that are kept by the parties to the business transaction.
3. A person shall keep a tax source document for at least three years after the end of the calendar year for the determination of the
tax liabilities of which such document is necessary.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Article 721 – Tax document
1. A tax document (the ‘TD’) shall be the document of the form determined by the Minister of Finance of Georgia, which is issued:
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a) when transporting goods within the country;
b) when supplying goods;
c) when providing services.
2. When the SD is issued, no obligation of issuing a consignment note or a tax invoice (including a special tax invoice) shall arise.
3. The SD shall be the VAT deduction document for a VAT payer.
4. If the SD is/is not issued, all the legal consequences that would follow in a respective case when a consignment note and/or a tax
invoice (including a special tax invoice) was/was not issued shall follow.
5. When the procedure for issuing and submitting the SD is not complied with, the measures of liability established by the
legislation of Georgia for an offence related to the procedure for issuing and submitting a consignment note or a tax invoice
(including a special tax invoice), respectively.
6. The SD may be issued and submitted in an electronic form.
7. The procedure for issuing and submitting the SD shall be defined by the order of the Minister of Finance of Georgia.
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Article 73 – Determining an object of taxation and tax liability in certain cases
1. Income shall be taxed even if its legitimacy is in question.
2. Income earned or a transaction performed in violation of tax legislation shall be taxed as provided for by the tax legislation of
Georgia.
3. If under a court decision, in the cases provided by the legislation of Georgia, income is subject to full collection in favour of the
budget, it shall not be taxed.
4. If any amount is used for the interests of a particular person, the amount shall be deemed to have been received by that person.
5. A tax authority may determine a person’s tax liabilities by using indirect methods (based on the volume of assets, operating
income and costs, by comparing information on the person with any other tax period of his/her business or with the data on other
taxpayers who are subject to the same taxes, as well as based on analyses of similar information):
a) if a person does not have accounting documents or an object of taxation cannot be determined based on accounting documents;
b) if there are more than one of the following conditions:
b.a) the increase in a person’s assets is not supported by appropriate documents;
b.b) the costs incurred by a person for economic activity and/or personal use exceed the declared income;
b.c) in the audited period specified under the relevant act of a tax authority on the commencement of a tax audit, two or more
cases of tax offences have been detected as a result of current tax control measures;
b.d) there is a substantial difference between the taxation-related data submitted/declared by a person to a tax authority and the
actual data recorded as a result of current tax control measures.
6. In transactions between related parties, income and costs shall be distributed the same way as in the case of a transaction
between unrelated persons.
7. When paying taxes, a person who sells goods/services primarily for cash applies the simplified rules established by the Minister
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of Finance of Georgia for recording revenues and costs. These rules shall not extend to the taxpayers who, for the purposes of
profit and income taxes, are obliged to keep or voluntarily keep records on an accrual basis or to the person who is registered as a
VAT-payer.
8. A tax authority may, in the case of exchange (barter) transaction of goods/services, define the sum of taxable amount by the
market price. The conditions and rules for the application of this paragraph, and the cases when this paragraph is not applied shall
be defined by the Minister of Finance of Georgia.
9. To determine tax liabilities, a tax authority shall have the right:
a) not to take into account business transactions of no substantial economic impact;
b) to change the classification of a business transaction based on its form and substance if the form of the transaction does not
correspond with its substance;
c) for the VAT purposes, to consider any several persons set up in the territory of Georgia as one taxable person, irrespective of
their formal/legal independence, if the major decisions with respect to their activities/management are made by one and the same
person and their places, types and contents of activities are identical. The cases and rules for the application of the right provided
for by this subparagraph shall be defined by the Minister of Finance of Georgia.
10. A taxable transaction performed in a foreign currency shall be translated into the national currency of Georgia in the following
order:
a) if there is an official exchange rate of lari defined by the National Bank of Georgia for a respective foreign currency as of the
transaction day, at this rate;
b) if there is no official exchange rate of lari defined by the National Bank of Georgia for a respective foreign currency as of the
transaction day, at the rate defined under the procedure determined by the Board of the National Bank of Georgia.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Chapter X – (Deleted)
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 74 – (Deleted)
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 75 – (Deleted)
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
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Article 76 – (Deleted)
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 77 – (Deleted)
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 78 – (Deleted)
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
SECTION V
INCOME AND PROFIT TAXES
Chapter XI – Income Tax
Article 79 – Taxpayers
An Income tax payer shall be:
a) a resident natural person;
b) a non-resident natural person earning income from a Georgian source.
Article 80 – Object of taxation
1. A resident natural person shall be taxed by income tax with respect to his/her taxable income, which is the difference between
the total income earned during a calendar year and deductions under this Code for that period.
2. A non-resident natural person conducting business through a permanent establishment in Georgia shall be taxed by income tax
with respect to his/her taxable income, which is the difference between the total income earned during a calendar year from a
Georgian source related to the permanent establishment and deductions under this Code for that period.
3. The gross income of a non-resident natural person that is not related to his/her permanent establishment in Georgia shall be
taxed under Article 134 of this Code at source without deductions, except as provided for by paragraphs 4 and 6 of this article.
4. A non-resident natural person who receives income from the sale of property shall pay income tax with respect to the gross
income earned during a calendar year from a Georgian source that is reduced by the deductions related to the receipt of such
income for that period.
5. The income from the sale of property provided for by paragraph 4 of this article shall be:
a) the surplus gained from the sale of ordinary shares of a resident legal entity or from the sale of a partner's share;
b) the surplus income earned from the assets referred to in Article 8(21) of this Code;
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c) the surplus gained from the sale of the property used for the economic activity provided for in Article 104(1)(k) or (l) of this
Code;
d) the surplus gained from the sale of other property.
6. The object of income taxation of a non-resident natural person, who receives a payment for leasing/renting of property from a
person who is not a tax agent under Article 154(1) of this Code, shall be the difference between the gross income earned from a
Georgian source during a calendar year and the sums of deductions related to the receipt of this income.
7. The object of income taxation of a natural person, who receives income from the organisation of a slot machine salon and/or the
organisation of games of chance in a systemic and electronic form, with regard to the said activity, shall be the difference between
the bets accepted from players and the winnings paid out to players.
71. The object of income taxation of a natural person, who receives income from the organisation of betting house games in the
systemic and electronic form as a result of participation of foreign citizens in the betting house games organised in a systemic and
electronic form, with regard to the said activity, shall be the difference between the bets accepted from players with foreign
citizenship and the winnings paid out to those players.
8. The object of income taxation of a person participating in games of chance organised with the use of slot machines and/or games
of chance and/or prize-winning games organised in the systemic and electronic form (except for a promotional draw organised in
the systemic and electronic form) shall be the sum withdrawn by him/her from an organiser of a slot machine salon or the
systemic and electronic gambling account (except for the sum withdrawn by the foreign citizens from the systemic and electronic
gambling account).
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Article 81 – Tax rate
1. A natural person's taxable income shall be taxed at the rate of 20%, unless otherwise provided for by this Code.
2. As a result of renting out the residential space to an organisation, legal or a natural person for residential purposes, the income
received by a natural person who makes no deductions from this income shall be taxed at the rate of 5%.
3. Surplus income gained by a natural person from the provision of a residential apartment (house) and of the land attached to it,
or from the provision of a vehicle, shall be taxed at the rate of 5%.
31. Taxable income received by a natural person from the organisation of a slot machine salon and/or the organisation of games of
chance in the systemic and electronic form, except for the taxable income of the organiser of games of chance in the systemic and
electronic form, as a result of participation of foreign citizens in the games of chance organised in the systemic and electronic
form, shall be taxed at 20%.
32. The sum provided for by Article 80(8) of this Code shall be taxed at 5%.
33. Taxable income received by the organiser of the games of chance in the systemic and electronic form and/or of the betting
house games in the systemic and electronic form, as a result of participation of foreign citizens in the games of chance organised in
the systemic and electronic form and/or in the betting house games organised in the systemic and electronic form, shall be taxed at
5%.
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4. For the purposes of paragraph 3 of this article, surplus income received from the provision of assets shall be determined
according to Article 82(4)(b) of this Code.
5. For the purposes of paragraph 2 of this article, the procedure for the maintenance of the register of persons renting out the
residential space and for the enjoyment of tax privileges by persons renting out the residential space to legal persons shall be
established by the Minister of Finance of Georgia.
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Law of Georgia No 134 of 13 December 2024 – website, 29.12.2024
Article 811 – (Deleted)
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Law of Georgia No 3015 of 26 December 2014 – website, 30.12.2014
Article 82 – Tax exemption
1. The following types of income of natural persons shall be exempt from income tax:
a) income of a non-resident earned while being employed at foreign diplomatic and other equivalent establishments in the
territory of Georgia;
b) grant, state pension, state compensation, state academic scholarship, state scholarship, allowances or lump sum payments
allocated from the budget and/or the amounts received by a natural person from budget reserve funds;
b1) benefit received from a non-entrepreneurial (non-commercial) legal person founded by the State within the scope of the
charitable activities;
b2) benefit received from a charitable organisation for financing treatment and/or medical service expenses;
b3) a pension contribution made to the individual pension account of a participant of the funded pension scheme under the Law of
Georgia on Funded Pension, benefits accrued on it and a pension/pension assets to be returned in accordance with Articles 32-
34(3) of the Law of Georgia on Funded Pension, except for:
b3.a) when a pension contribution has been made erroneously or excessively, the sum corresponding to the amount of the pension
contribution made erroneously or excessively and to be returned to a participant of the funded pension scheme/a natural person,
and the benefits accrued on it;
b3.b) the sum corresponding to the amount of a pension contribution to be returned to an employee withdrawn from the funded
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pension scheme under Article 22 of the Law of Georgia on Funded Pension, and the benefits accrued on it;
b3.c) the sum corresponding to the amount of pension assets to be returned to a participant of the funded pension scheme on the
ground of his/her leaving Georgia for good under Article 341 of the Law of Georgia on Funded Pension.
Note: where so provided for by subparagraphs b3.a, b3.b and b3.c) of this paragraph, the respective sum shall be taxed at a rate
defined by Article 81(1) of this Code;
b4) within the voluntary private pension scheme:
b4.a) pension contributions of up to GEL 6 000 in total made by a participant and/or in his/her favour during the year;
b4.b) benefits received by a participant as a result of his/her participation in the pension scheme, except for the withdrawal of
pension assets before the occurrence of cases defined by Article 40(1) of the Law of Georgia on Voluntary Private Pension;
b4.c) when the pension assets accrued on the personal pension account of a participant are received through programmed
withdrawal or as an annuity when he/she achieves the pension age, retires earlier or becomes disabled. In addition, if the pension
is received as a lump-sum payment, except when a beneficiary withdraws the pension, the pension contributions made within the
privilege provided for by subparagraph b4.a) of this paragraph shall be subject to taxation at the rate defined by Article 81(1) of
this Code;
c) monetary and other awards to sportsmen and their coaches for winning and/or taking podium places in Olympic Games, Chess
Olympiads, World and/or European Championships, European Games, World Youth Olympic Games and/or European Youth
Olympic Festivals, as well as monetary and other awards to medical personnel of Georgian teams; also other cash prizes
determined under an Ordinance of the Government of Georgia for sportsmen and their coaches and for medical personnel in
individual Olympic and Non-Olympic games and in particular types of sports games;
d) alimony;
e) the value of property (income) received by a natural person as a result of dissolution of marriage;
f) natural person’s:
f.a) surplus gained from the sale of a residential apartment (house) along with the land attached to it owned for more than two
years;
f.b) surplus gained from the sale of a vehicle owned for more than six months after registration of title;
f.c) surplus gained from the supply of assets owned for more than two years, except for usage of assets by the transferor for
economic activity before their supply and/or for cases under subparagraphs (f.a) and (f.b) of this paragraph.
Note: mere holding of securities/share for receiving a dividend/interest shall not be considered the usage of assets for economic
activity for the purpose of this subparagraph. In addition, the usage of assets for economic activity shall not be taken into account
if two years have passed from the moment when their usage for economic activity ended till their supply;
g) the value of property received as a gift or inherited by first and second line heirs during a fiscal year;
h) the value of property of up to GEL 1 000 received as a gift from a natural person during a tax year, except for the value of
property received as a gift by an employee from the employer;
i) the value of the property of up to GEL 150 000 received as a gift or by inheritance during a tax year by third and fourth line
heirs;
j) (Deleted – 15.12.2022, No 2400);
j1) the monetary payment paid for the donation of blood or blood component by a natural person (donor) before 1 April 2030;
k) taxable income earned from the primary supply of agricultural products produced in Georgia by a natural person engaged in
agricultural production until 1 January 2028 if the gross income earned by the natural person from such supply during the
calendar year does not exceed GEL 200 000;
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l) gain arising from the receipt of property (except for movable property transferred to state ownership) through privatisation (or
free of charge), and from gratuitous receipt of apartments by the victims of earthquake or other natural disasters in exchange for
damaged apartments in the same populated area or by eco-migrants in other populated areas;
l1) gain arising from the acknowledgment of the property right according to the Law of Georgia on Recognition of Property Rights
of the Parcels of Land Possessed (Used) by Natural Persons and Legal Entities under Private Law;
m) compensations received within a privatisation program by a refugee, a person with supplementary protection, or by an
internally displaced natural person in exchange for a temporary residence; also, for internally displaced persons, the value of
property granted to them by the State and income received from the initial sale of that property;
n) (Deleted – 14.7.2020, No 6817);
o) (Deleted – 28.6.2019, No 4906);
p) (Deleted – 23.12.2107, No 1935);
q) income earned by a non-resident from a Georgian source as a result of risk insurance or reinsurance by a company, organisation
and/or entrepreneur natural person;
r) income earned by non-residents from leasing out the property that do not belong to the non-resident’s permanent establishment
in Georgia;
s) interest income from government debt securities or debt securities of the National Bank of Georgia, the Legal Entity under
Pubic Law – the Deposit Insurance Agency, and of an international financial institution. The list of international financial
institutions shall be determined by an ordinance of the Government of Georgia;
t) surplus income from the sale of government debt securities or debt securities of the National Bank of Georgia, the Legal Entity
under Pubic Law – the Deposit Insurance Agency, and of an international financial institution and the income received from the
interests accrued by funds placed in the accounts at the National Bank of Georgia. The list of international financial institutions
shall be determined by an ordinance of the Government of Georgia;
t1) income gained by a resident legal person from the supply of the equity securities issued through a public offering in Georgia
and allowed for trading on an organised market recognised by the National Bank of Georgia;
t2) income gained by a resident legal person as an interest from the loan securities issued before 1 January 2028 through a public
offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia.
t3) income gained by a resident legal person from the supply of the equity securities issued through a public offering in Georgia
and allowed for trading on an organised market recognised by the National Bank of Georgia;
u) income (including gain) received by a resident natural person, which does not belong to Georgian source income;
v) an appropriate allowance paid by the employer to an employee of the Ministry of Internal Affairs of Georgia, an employee of
the State Security Service of Georgia, or to a military servant maimed in the course of his/her duty or those who became disabled
in the course of this duty, and in the event of death of the said person – an allowance paid by his/her employer to the family (heir)
of this person;
w) income received from lottery, the value of which does not exceed GEL 1 000;
x) income earned by a partnership from the transfer of property to its member (co-owner), provided the members of the
partnership are only natural persons, the composition of the members of the partnership did not change from the foundation of
the partnership up to the transfer (distribution) of property and the partnership is not a VAT payer at the moment of the
distribution. For the purposes of this subparagraph, the transfer of a partner’s interest to his/her heir in the case of the partner’s
death or the sale of a partner’s interest under the Law of Georgia on Enforcement Proceedings shall not be regarded as a change in
the composition of the partnership;
y) salary income earned by a non-resident natural person, if the employment is performed within the territory of Georgia for not
more than 30 calendar days during a tax year and the payer of such income (salary) is a non-resident employer, except where such
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expenses are attributed to the expenses of the non-resident’s permanent establishment, irrespective of whether such expenses are
paid by such permanent establishment;
z) surplus received from the transfer of real estate to a partner natural person in exchange for his/her share in the enterprise by
way of liquidation or capital reduction of such company, if more than two years have elapsed from the creation of the natural
person’s title to that share of the enterprise;
z1) salary paid by a person engaged in agricultural production before 1 January 2028 within the scope of that activity, if the
employer’s gross income received from that activity does not exceed GEL 200 000.
z2) income received by an organiser of a gambling club or a betting house from the said activity;
z21) profit received by foreign citizens as a result of participation in the games of chance organised in the systemic and electronic
form and/or in the betting house games organised in the systemic and electronic form and the sum withdrawn from the systemic
and electronic gambling account;
z3) the value of property received free of charge from a charitable organisation by a person duly registered in the unified database
of socially vulnerable persons (who receives subsistence allowance that can be evidenced by the relevant documents), by a person
maimed in the fight for the territorial integrity of Georgia, as well as by a family member of a person killed in the fight for the
territorial integrity of Georgia;
z4) gain derived from the transfer of immovable property by an administrative authority (employer) to a staff member (employee)
for consideration or free of charge;
z41) gain derived from a gratuitous transfer by an administrative authority to an employee of fuel intended for a vehicle which is
in the employee’s personal possession in the course of his/her official duty;
z5) compensation payable to a person for the provision of services of the surety specified in Article 249 of this Code, of the surety
specified in the Civil Code of Georgia, or easement services free of charge, and the gain received by recipients of those gratuitous
services;
z6) gain derived by a hotel room owner from gratuitous hotel services (hotel accommodation) provided to him/her for maximum
60 days during a calendar year by a tourist enterprise and/or by the person(s) hired under an agreement by the tourist enterprise
for the functioning/operation of the hotel;
z61) income received by a notary in the form of a financial aid from the LEPL Notary Chamber of Georgia under the Law of
Georgia on Notaries in a high-mountain settlement or in a settlement where notary services were not duly available at the
moment of the appointment of a notary.
z7) income earned by a person under the bankruptcy regime after opening of the bankruptcy regime under the procedure
established by the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors;
z71) income earned by a natural person as a result of being employed by a person under the bankruptcy regime;
z72) compensation for the property confiscated under Article 19 of the Constitution of Georgia;
z73) income earned from the activity carried out within the status of a high-mountain settlement enterprise by an individual
entrepreneur who enjoys the status of a high-mountain settlement enterprise – for 10 calendar years after the granting of the
relevant status (including the calendar year in which the status was granted);
z74) income earned from supplying the surplus energy produced by a retail consumer, an owner of a micro power plant to a
distribution licensee;
z75) income earned by a person having the status of a special enterprise from an activity under Article 242(2)(a) and (b) of this
Code.
Note: a tax privilege under t1–t3 of this paragraph shall also apply when the loan/equity securities are allowed for trading on an
organised market before its recognition by the National Bank of Georgia. In addition, the privilege shall be effective from the date
of recognition of the organised market by the National Bank of Georgia.
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2. Income tax shall not be levied on:
a) taxable income up to GEL 3 000 earned by the following natural persons during a calendar year:
a.a) citizens of Georgia who are veterans of World War II, veterans of military operations for the territorial integrity, freedom and
independence of Georgia, and veterans of military operations in the territory of other states;
a.b) a person awarded with an honorary title of ‘Kartvlis Deda’ (Mother of Georgia);
a.c) a single parent;
a.d) a person who has adopted a child (for one year from adoption);
a.e) a person has taken a child under foster care;
a.f) the taxable salary income received from a budgetary organisation in a high-mountain settlement during a calendar year by a
person with three or more children (having three or more than three dependent children under age 18) who resides permanently
in a settlement. Income tax on the taxable salary income of up to GEL 3 000 received from a budgetary organisation in a high-
mountain settlement during a calendar year by a person with one or two children (having one or two dependent children under
age 18) who resides permanently in a settlement shall be reduced by 50%.
b) the taxable income of up to GEL 6 000 earned during a calendar year by a person with a disability from childhood, and by a
person with a severe or persistent disability;
b1) a taxable income of up to GEL 6 000 earned during a calendar year by a person who received serious damage to health during
the participation in international peacekeeping operations for the maintenance and restoration of peace and security or in other
peacekeeping activities in accordance with the legislation of Georgia;
c) taxable income of up to GEL 6 000 earned by a person with the status of a person permanently residing in a high-mountain
settlement from an activity in a high-mountain settlement during a calendar year, except for the salary income received from a
budgetary organisation, and a medical institution established by the state or a municipality.
3. If in the cases provided for in the second paragraph of this article an income tax payer becomes eligible to more than one tax
privileges, he/she shall use the highest of the tax privileges.
4. For the purposes of this article:
a) The two-year term of owning an asset shall commence:
a.a) from the date of the preparation of a certificate of title for the purpose of registration with the registration authority; if an
asset that is registered with the registration authority as a single property in terms of its title deed is divided, the two-year period
of ownership of the received asset shall be calculated from the date of ownership of the asset before its division.
a.b) if a title is not registered with the registration authority – from the moment of creation of the title;
a1) for the purposes of having assets in ownership for a 2-year term, a total term of ownership of a natural person and of a
testator/donator, whose first line heir is this natural person, shall be taken into account;
a2) the moment of supplying, including of selling assets, shall be deemed the date of preparation of the document on the basis of
which the registration of transfer of the right of ownership to another person has been carried out with a registration authority;
and if the registration of the right of ownership is not carried out with a registration authority, then the moment of transferring
the right of ownership;
b) ‘surplus gained from the sale’ of an asset shall be calculated as:
b.a) the difference between the supply price of the asset and its purchase price at the moment of the creation of title to it;
b.b) the difference between the supply price of an asset and its market price at the moment of gratuitous receipt, provided the title
to the asset has been received free of charge.
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c) when receiving property as a gift and/or by will the following persons shall be deemed as first, second, third and fourth line
heirs:
c.a) first line heirs – spouse, child, adopted child, grandchild, great grandchild and his/her child, parent, adoptive parent;
c.b) second line heirs – sister, brother, niece/nephew and their children;
c.c) third line heirs – grandmother and grandfather, parents of grandmother and parents of grandfather both maternal and
paternal;
c.d) fourth line heirs – uncle (mother’s brother and father’s brother), aunt.
5. The rule for the application of a tax privilege in relation to the income received from a payment source according to the tax year
shall be determined by the Minister of Finance of Georgia.
Law of Georgia No 3882 of 7 December 2010 – LHG III, No 72, 22.12.2010, Art. 428
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5371 of 6 December 2011 – website, 20.12.2011
Law of Georgia No 5452 of 9 December 2011 – website, 22.12.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5791 of 13 March 2012 – website, 23.3.2012
Law of Georgia No 6053 of 24 April 2012 – website, 27.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 6502 of 19 June 2012 – website, 2.7.2012
Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013
Law of Georgia No 1046 of 6 September 2013 – website, 23.9.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2950 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 3942 of 8 July 2015 – website, 15.7.2015
Law of Georgia No 4037 of 16 July 2015 – website, 28.7.2015
Law of Georgia No 4611 of 10 December 2015 – website, 22.12.2015
Law of Georgia No 4647 of 16 December 2015 – website, 25.12.2015
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Law of Georgia No 4611 of 10 December 2015 – website, 22.12.2015
Law of Georgia No 4647 of 16 December 2015 – website, 25.12.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 4842 of 4 March 2016 – website, 9.3.2016
Law of Georgia No 5491 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 854 of 17 May 2017 – website, 2.6.2017
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 2476 of 6 June 2018 – website, 21.6.2018
Law of Georgia No 1607 of 27 June 2018 – website, 6.7.2018
Law of Georgia No 3308 of 21 July 2018 – website, 6.8.2018
Law of Georgia No 3383 of 5 September 2018 – website, 24.9.2018
Law of Georgia No 3440 of 20 September 2018 – website, 5.10.2018
Law of Georgia No 3600 of 31 October 2018 – website, 21.11.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 1652 of 9 June 2022 – website, 23.6.2022
Law of Georgia No 2400 of 15 December 2022 – website, 27.12.2022
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3540 of 21 September 2023 – website, 12.10.2023
Law of Georgia No 3608 of 1 November 2023 – website, 20.11.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
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Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Law of Georgia No 143 of 13 December 2024 – website, 29.12.2024
Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025
Law of Georgia No 879 of 26 June 2025 – website, 7.7.2025
Law of Georgia No 1024 of 11 November 2025 – website, 14.11.2025
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Law of Georgia No 1475 of 1 April 2026 – website, 1.4.2026
Chapter XII – Special Tax Treatments
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 83 – Special tax treatments
Special tax treatments shall apply to:
a) natural persons having the status of a micro business;
b) entrepreneur natural persons having the status of a small business;
c) persons having the status of a fixed tax payer.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 84 – Micro business
1. The status of a micro business may be granted to a natural person who does not use the hired labour and conducts economic
activity independently, the gross receivable income from which during a calendar year does not exceed GEL 30 000.
2. The GEL 30 000 limit set by the first paragraph of this article does not apply to the types of activities identified by the
Government of Georgia in agreement with the Financial-Budget Committee of the Parliament of Georgia.
3. In agreement with the Financial-Budget Committee of the Parliament of Georgia, the Government of Georgia may prohibit the
conduct of certain activities, for which the status of micro business cannot be granted to a natural person.
4. In agreement with the Financial-Budget Committee of the Parliament of Georgia, the Government of Georgia may determine
the types of income not taxable under special tax treatment and for the purposes of the first paragraph of this article shall not be
included in gross income.
5. The status of a micro business is granted, revoked and the certificate of a micro business is issued as prescribed by the Minister
of Finance of Georgia.
Article 85 – Granting the status of a micro business
1. A natural person who meets the conditions set out in Article 84 of this Code may apply to a tax authority for the status of a
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micro business. The tax authority shall issue a certificate of a micro business.
2. The status of a micro business in the current fiscal year shall be revoked if:
a) a natural person has applied to a tax authority for revocation of the status of a micro business or for receiving the status of a
small business;
b) after the inventory conducted by a tax authority it has been established that the inventory balance of a natural person having
the status of a micro business exceeds GEL 45 000.
c) a natural person has been registered as a VAT payer.
3. If a person having the status of a micro business does not apply to a tax authority for the status of a small business within 15 days
after violating the requirement (limit on the amount of gross income) of Article 84(1) of this Code, his/her status of a micro
business shall be revoked and shall be removed from special tax treatment.
4. If a natural person does not comply with the requirement of Article 84(3) of this Code, a tax authority shall revoke his/her status
of a micro business and remove him/her from special tax treatment.
5. If the status of micro business of a natural person is revoked, the income of the natural person at that moment shall be taxed:
a) at the moment of receiving the status of small business – in accordance with the procedure established for micro business;
b) in other cases – in accordance with Articles 79-82 of this Code.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 86 – Exemption of a micro business from tax
A natural person having the status of a micro business shall not pay income tax.
Article 87 – Obligations of a micro business
1. When drawing up a tax source document, a person having the status of a micro business shall indicate his/her status and status
certificate number in the document.
2. A person having the status of a micro business shall keep the tax source document issued by or to him/her.
Article 88 – Small business
1. The status of a small business may be granted to an entrepreneur natural person.
2. In agreement with the Financial-Budget Committee of the Parliament of Georgia, the Government of Georgia may prohibit the
conduct of a certain activity for which the status of a small business cannot be granted to a natural person.
3. In agreement with the Financial-Budget Committee of the Parliament of Georgia, the Government of Georgia may determine
the types of income that will not be taxed under the special tax treatment and will not be included in the gross income when
calculating the GEL 500 000-limit of the gross income received during a calendar year determined for a natural person having the
status of a small business, and when calculating the GEL 700 000-limit of the gross income – in the case of wine tourism operators
and agro tourism operators.
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
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Law of Georgia No 3922 of 13 December 2023 – website, 27.12.2023
Article 89 – Granting the status of small business
1. An entrepreneur natural person who meets the conditions set out in Article 88 of this Code may apply to a tax authority for a
status of a small business. The tax authority shall grant a certificate of small business.
2. The status of small business shall be revoked if:
a) the gross income received by a person from his/her economic activities according to 2 calendar years has exceeded GEL 500 000
in each calendar year, and GEL 700 000 – in the case of wine tourism operators and agro tourism operators;
b) a person has applied to a tax authority with this request before the end of the calendar year;
c) a person conducts an activity under Article 88(2) of this Code;
d) a person has been fined at least three times within a calendar year for failing to comply with the cash register usage procedures;
e) a person has failed to meet the requirement provided for by Article 88(1) of this Code.
3. In the case provided for by paragraph 2(a) of this article, the status of small business shall be considered revoked from the
beginning of a year following the calendar year.
31. In the case provided for by paragraph 2(b) of this article, the status of small business shall be considered revoked from the first
day of a month following the month when a person has applied to a tax authority.
4. If the status of a small business is revoked on the ground under paragraph 2(c or d) of this article, the status of a small business
shall be considered revoked from the beginning of the calendar year.
5. Where so provided for by paragraph 2(e) of this article, the status of small business shall be considered revoked from the date
when an appropriate ground for this originated.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3922 of 13 December 2023 – website, 27.12.2023
Article 90 – Taxable income of small business and tax rates
1. Taxable income of a person having the status of a small business shall be taxed at 1%, except as provided for paragraph 2 of this
article.
2. Taxable income of a person having the status of a small business shall be taxed at 3% if his/her gross income received from the
economic activities of this person has exceeded GEL 500 000, and in the case of wine tourism operators and agro tourism operators
if the said gross income has exceeded GEL 700 000. A person having the status of a small business shall be taxed at the rate
determined under this paragraph from the beginning of a respective month (a month when the excess of the GEL 500 000-limit,
and in the case of wine tourism operators and agro tourism operators – the GEL 700 000-limit of the gross income has been
recorded) until the end of the calendar year.
3. Taxable income of a small business consists of the incomes earned from a Georgian-based source, except for the salary income
and the income earned from a type of income defined in Article 88(3) of this Code.
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Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 3922 of 13 December 2023 – website, 27.12.2023
Article 91 – Principles of accounting for small business income and costs
1. A person having the status of a small business shall maintain a special book of records. The procedure for maintaining the book
(including in an electronic form) shall be defined by the order of the Minister of Finance of Georgia.
2. (Deleted – 30.5.2018, No 2391).
3. An entrepreneur natural person having the status of a small business shall keep a tax source document issued to or by him/her.
4. (Deleted – 30.5.2018, No 2391).
5. The loss incurred by a small business during a tax year shall not be carried forward to the next year, unless the taxpayer is
removed from special tax treatment.
6. The procedure for recording the inventory balance available when the status of a small business is revoked for an entrepreneur
natural person having the status of a small business shall be defined by the order of the Minister of Finance of Georgia.
7. (Deleted – 30.5.2018, No 2391).
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Article 92 – Registration of a small business as a VAT payer
1. An entrepreneur natural person having the status of small business, who has become obligated to obtain mandatory registration
as a VAT payer, shall pass the registration under Article 165 of this Code.
2. When an entrepreneur natural person having the status of a small business becomes liable for mandatory registration as a VAT
payer, he/she shall record the inventory balance available at that moment.
3. Upon registration as a VAT payer, an entrepreneur natural person having the status of a small business may obtain a VAT
deduction for the inventory balance referred to in the second paragraph of this article as provided for by this Code, provided
relevant documents are available.
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 93 – Filing micro and small business tax returns
1. A natural person having the status of micro business shall file a tax return with a tax authority according to the place of tax
registration before 1 April of the year following a tax year.
11. A tax return of a person having the status of small business shall be filed with, and a tax shall be paid to a tax authority not later
than the 15th day of a month following the accounting month.
2. A person having the status of micro business shall file a tax return with a tax authority within 30 business days after he/she
terminates his/her economic activities in Georgia.
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3. (Deleted – 20.12.2011, No 5556).
4. Tax return filing procedures for persons having the status of micro or small business shall be prescribed by order of the Minister
of Finance of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 94 – Current taxes of small and micro businesses and procedure for withholding at source
1. A natural person having the status of a micro business and a natural person having the status of a small business shall not pay
current taxes.
2. An entrepreneur natural person having the status of a small business shall pay current taxes to the budget according to the
annual tax paid during the previous tax year in the following amounts:
a) by not later than 15 May – 25%;
b) by not later than 15 July – 25%;
c) by not later than 15 September – 25%;
d) by not later than 15 December – 25%.
3. A natural person having the status of micro business shall not withhold tax at source if paying for the services received.
4. A salary of up to GEL 6 000 paid in total during a calendar year by a person having the status of a small business to hired persons
shall not be taxed at source if there is one of the following conditions:
a) he/she is registered as an individual entrepreneur and is granted the status of a small business within the same calendar year;
b) the gross income he/she received during the previous calendar year does not exceed GEL 50 000.
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Article 95 – Tax control over small and micro businesses
1. Tax authorities may conduct the following current tax control measures with respect to persons having the status of small and
micro businesses:
a) test purchase of goods/services;
b) visual inspection;
c) checking the observance of rules for the use of cash registers;
d) time study;
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e) stocktaking.
2. A tax authority may determine the income of a person having the status of micro business by indirect methods in accordance
with the procedures established by the Minister of Finance of Georgia.
Article 951 – Flat tax payers
A fixed tax payer may be a person who is not a VAT payer and who conducts one or more activities subject to a fixed tax.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 952 – Activities taxable with flat tax
The types of activities subject to a flat tax and in the case of the activities taxable at the rate specified in Article 953(1)(a) of this
Code, the activity taxable with a flat tax according to the types of activity shall be determined by the Government of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 953 – Flat tax rate
1. A flat tax rate according to the types of activity determined by the Government of Georgia may be:
a) from GEL 1 to GEL 2 000 for an object of taxation;
b) 3% of the revenues from taxable activity.
2. In the cases provided in paragraph 1(a) of this Article, a flat tax rate according to types of activity shall be determined by the
Government of Georgia to the extent of the amount determined by that subparagraph. At the same time, the Government of
Georgia may determine different flat tax rates according to the municipalities for the same types of activities taxable at a flat tax
rate.
3. In the case provided for in paragraph 1(b) of this article conditions and types of taxable activities according to the place of
business shall be determined by the Government of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 954 – Granting the status of a flat tax payer
1. A person who meets the requirements of Article 951 of this Code may apply to a tax authority for the status of a flat tax payer
and move to a flat tax regime, for which a certificate of a flat tax payer is issued.
2. A person may move to a flat tax regime in any month of the reporting year. At the same time, a person shall be deemed to have
the status of a flat tax payer and, accordingly, to be a flat tax payer from the first day of the month following the month in which
the person is granted the status of a flat tax payer.
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3. The procedures for granting and revoking a flat tax payer status and issuing a flat tax payer certificate shall be determined by
order of the Minister of Finance of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Article 955 – Conditions of flat rate taxation
1. In addition to the activity taxable by a flat tax, a flat tax payer may conduct only activities permitted by the Government of
Georgia.
2. Income earned from an additional activity referred to in the first paragraph of this article shall be taxed according to regular
procedures.
3. Income earned from the activity taxable by a flat tax shall not be included in the gross income of a flat tax payer and shall not be
subject to subsequent taxation.
4. A flat tax payer shall not pay current taxes according to a flat tax.
5. When preparing tax source documents, a flat tax payer shall indicate a flat tax payer status and a flat tax payer certificate
number.
6. A flat tax payer shall retain the tax source document issued to or by him/her.
7. The procedure for payment and reporting of flat tax shall be determined by order of the Minister of Finance of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 956 – Revoking a flat tax payer status
1. A flat tax payer status shall be revoked if:
a) a person ceases the activity taxable by a flat tax;
b) a person applies to a tax authority for revocation of a flat tax payer status;
c) a person conducts activities different from the additional activities permitted by the Government of Georgia for a flat tax payer;
d) a person becomes liable to become registered as a VAT payer in respect of the additional activity permitted by the Government
of Georgia for flat tax payers, or voluntarily becomes registered as a VAT payer.
2. If one of the conditions for revocation of the status of a flat tax payer occurs (except for paragraph 1(b) of this article), a person
shall apply to a tax authority for revocation of a flat tax payer status not later than 10 business days after the condition occurs.
3. The status of a flat tax payer shall be deemed revoked from the day when the condition for revocation of the status of a flat tax
payer specified in the first paragraph of this article occurs.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Chapter XIII – Profit Tax
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
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Article 96 – Profit tax payers
Profit tax payers shall be:
a) resident enterprises;
b) non-resident enterprises that conduct business in Georgia through a permanent establishment and/or earns income from a
Georgian source.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Article 97 – Object of profit taxation
1. The object of profit taxation of a resident enterprise (except as provided for by paragraphs 2, 8-91 and 93 of this article) shall
be:
a) the distributed profit;
b) the expenses borne or other payments not related to the economic activity;
c) free delivery of goods/services and/or transfer of funds;
d) the representation expenses paid in excess of the limited amount determined by this Code.
2. The object of profit taxation of an organisation conducting economic activities shall be:
a) the costs incurred, or other payments not connected with economic activities and/or which are not related to the objective of
the organisation’s activities (including those not connected with charity activities or not related to the objective of a grant
agreement);
b) the free supply of goods/provision of services, and/or transfer of financial resources if it is not related to the objective of the
organisation’s activities;
c) the entertainment costs paid in excess of the limited amount determined under this Code.
3. The object of profit taxation of a non-resident enterprise conducting business in Georgia through a permanent establishment
shall be, on the basis of the activity of its permanent establishment, disbursements made/expenses paid by the non-resident
enterprise, or the permanent establishment as provided for under paragraph 1 of this article.
4. Income earned by a non-resident enterprise from a Georgian source, which does not belong to its permanent establishment,
shall be taxed at the source without deductions in accordance with Article 134 of this Code, except as provided for in paragraphs 5,
6 and 11 of this article.
5. The object of profit taxation of a non-resident enterprise earning income from the sale of property under paragraph 6 of this
article, which is not related to the activity of its permanent establishment in Georgia, shall be the difference between the gross
income earned from a Georgian source during a calendar year and the deduction amounts with respect to earning of the income.
6. Income earned from the sale of property under paragraph 5 of this article shall be:
a) income gained from the sale of ordinary shares or partner's equity of a resident legal entity;
b) income gained from the sale of assets under Article 8(21) of this Code;
c) income gained from the sale of property under Article 104(1)(j) or (k) of this Code;
d) income gained from the sale of other property.
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7. If payments/disbursements under Articles 981 – 984 of this Code are made in a non-monetary form, the object of profit taxation
shall be determined by the market price of the goods supplied/services delivered, and if the market price of the goods
supplied/services delivered includes the value-added tax, the object of profit taxation shall be determined by the market price,
without the value-added tax.
8. The difference between the gross income gained during a calendar year and the amounts of the deductions provided for by this
Code shall be the object of profit taxation for:
a) a person that gains profit as a result of oil and gas operations based on the “existing agreements” defined by the Law of Georgia
on Oil and Gas, with regard to this profit;
b) a party to the Main Export Pipeline project as defined by the Agreement Among Georgia, the Azerbaijan Republic and the
Republic of Turkey Relating to the Transportation of Petroleum Via the Territories of the Azerbaijan Republic, Georgia and the
Republic of Turkey Through the Baku-Tbilisi-Ceyhan Main Export Pipeline, with regard to the profit gained within this project;
c) a party to the South Caucasus Pipeline project defined by the Agreement between Georgia and the Azerbaijan Republic Relating
to the Transit, Transportation and Sale of Natural Gas in and beyond the Territories of Georgia and the Azerbaijan Republic
Through the South Caucasus Pipeline System, with regard to the profit gained within this project.
9. In case of the organisation of betting house games in the systemic and electronic form, the object of profit taxation of a person
with regard to the said activity shall be defined under Article 309(16) of this Code (except for the profit received by the organiser
of betting house games in the systemic and electronic form as a result of participation of foreign citizens in the betting house
games in the systemic and electronic form).
91. The object of profit taxation of a person, in case of the organisation of a slot machine salon and/or the organisation of games of
chance in a systemic and electronic form, with regard to the said activity, shall be the difference between the bets accepted from
players and the winnings paid out to players.
92. In cases provided for by paragraphs 9, 91 and 93 of this article, for identification of the amount of profit received from the
activities provided for by the same paragraphs, it shall be deemed that, during distribution of dividends by a person, this amount is
paid out in the first place.
93. In case of participation of foreign citizens in betting house games organised in the systemic and electronic form, the object of
profit taxation of a person with regard to the said activity shall be the difference between the bets accepted from players with
foreign citizenship and the winnings paid out to those players.
10. For the purposes of paragraphs 1–3 of this article, the amount subject to profit taxation shall be calculated by dividing the sum
of a disbursement made/expense paid according to the object of taxation determined under the same paragraphs by 0.85.
11. The object of profit taxation of a non-resident enterprise, which receives a payment for leasing/renting of property from a
person who is not a tax agent under Article 154(1) of this Code, shall be the difference between the gross income earned from a
Georgian source during a calendar year and the sums of deductions related to the receipt of this income.
12. The object of profit taxation of a banking institution, credit union, microfinance organisation or a loan provider shall be the
difference between the gross income earned during a calendar year and the sums of deductions under this Code.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Article 98 – Tax rate
1. The profit tax rate shall be 15%, except as provided for by paragraphs 2, 4, 5 and 6 of this article.
2. Profit gained from oil and gas operations as a result of implementation of the ’existing agreements’ defined by the Law of
Georgia on Oil and Gas shall be taxed at 10%, if these agreements were signed before 1 January 1998.
3. (Deleted – 13.12.2023, No 3902).
4. The taxable profit of a banking institution, credit union, microfinance organisation or a loan provider shall be taxed at 20%.
5. Taxable profit of the organiser of the games of chance in the systemic and electronic form and/or of the betting house games in
the systemic and electronic form, as a result of participation of foreign citizens in the games of chance organised in the systemic
and electronic form and/or in the betting house games organised in the systemic and electronic form, with regard to the said
activity, shall be taxed at 5%.
6. Taxable profit received from the organisation of a slot machine salon and/or the organisation of games of chance in the systemic
and electronic form, except for the taxable profit of the organiser of games of chance in the systemic and electronic form, as a
result of participation of foreign citizens in the games of chance organised in the systemic and electronic form, shall be taxed at
20%.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Law of Georgia No 134 of 13 December 2024 – website, 29.12.2024
Article 981 – Distributed profit
1. Distributed profit shall be a profit distributed by an enterprise to its partner as a dividend in a monetary or non-monetary form.
2. The following shall not be deemed as distributed profit:
a) a payment/disbursement made in cash or in kind at the time of liquidation of an enterprise or at the time of buying out a
share/interest, which does not exceed the amount of contribution made by a partner to the capital (outstanding and additional
paid-in capital). Increase of the capital of an enterprise as a result of an operation conducted under sub-paragraph b) of this
paragraph for the purposes of this sub-paragraph shall not be considered a contribution made by a partner to the capital
(outstanding and additional paid-in capital);
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b) a payment made to a partner of an enterprise by transferring a share/interest of the enterprise into ownership, except for
transferring by a resident legal person the equity securities issued through a public offering in Georgia and allowed for trading on
an organised market recognised by the National Bank of Georgia;
c) distribution of dividends to persons provided for by Article 2(3) of the Law of Georgia on Entrepreneurs (except for an
individual enterprise and a person exempted from profit tax under this Code);
d) transfer of assets to the state and/or a municipality by an enterprise through capital reduction if more than 50% of
shares/interest of the enterprise is in the ownership of the state and/or the municipality;
e) distribution by an enterprise of a dividend received from a foreign enterprise (except for a person registered in a country with
preferential tax treatment);
f) further distribution of the received dividend by a person provided for by Article 21(1)(b) of the Tax Code of Georgia (except for
a permanent establishment of a foreign enterprise), who has moved the place of management to Georgia.
3. For the purposes of this article, distributed profit of a permanent establishment of a non-resident enterprise shall be deemed a
disbursement made to the non-resident enterprise in cash or in kind out of the profit gained as a result of the activity of the
permanent establishment (taking away by the non-resident enterprise of the profit allotted to its permanent establishment). A
permanent establishment shall be allotted a profit it might have gained as an independent enterprise conducting the same or
similar activity and being in the same or similar conditions.
4. The following shall be deemed as distribution of profit:
a) any operation performed by an enterprise with a related party (who is not subject to profit tax according to objects of taxation
under Article 97(1, 3)) if the price of a transaction concluded between them is different from its market price and their relation
affects the outcome of the transaction. In such a case the amount of distributed profit shall be:
a.a) the difference between the market price of a transaction and the income gained/to be gained if the market price of the
transaction exceeds the income gained/to be gained;
a.b) the difference between the costs incurred as a result of a transaction and the market price of the transaction if the costs
incurred as a result of the transaction exceeds the market price of the transaction;
b) conduct of a controlled transaction if the established conditions for the transaction fail to satisfy the market principle. In such a
case, the amount of distributed profit shall be determined by the adjustment amount calculated under the procedure established by
Chapter XVII of this Code;
c) any operation performed by an enterprise with a person exempt from income tax/profit tax (except for a budget organisation,
the Legal Entity under Public Law – the Deposit Insurance Agency and the National Bank of Georgia) if the price of a transaction
concluded between them is different from its market price. In such a case the amount of distributed profit shall be:
c.a) the difference between the market price of a transaction and the income gained/to be gained if the market price of the
transaction exceeds the income gained/to be gained;
c.b) the difference between the costs incurred as a result of a transaction and the market price of the transaction if the costs
incurred as a result of the transaction exceeds the market price of the transaction.
5. For the identification of the amount under paragraph 2(e) of this article it shall be deemed that this amount is to be paid first
when a dividend is distributed by an enterprise.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 854 of 17 May 2017 – website, 2.6.2017
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021
Article 982 – Costs incurred or other payments not related to economic activity
1. For the purposes of this article, costs not related to economic activity shall be:
a) costs that are not documented if this obligation is established under this Code;
b) costs the purpose of payment of which is not to gain profit, income or compensation;
c) costs paid for goods/services purchased from a natural person having the status of a micro business, except when the income
gained from the delivery of goods/services by a person having this status is taxed under the general rule, or when a consignment
note/a document of a form determined by the Minister of Finance of Georgia is issued upon the supply/purchase of goods;
d) costs paid for goods/services purchased from a person having the status of a fixed taxpayer within the scope of an activity taxed
at a fixed rate (except for an activity to be taxed at a fixed rate under Article 953(1)(b) of this Code);
e) the interest paid for a credit (loan) above the annual interest rate established by the Minister of Finance of Georgia;
f) costs paid by a person (except for a special trade company) for purchasing foreign goods from a special trade company in the
amount exceeding the customs value of the goods, except for the costs not related to payments to the special trade company.
2. Costs paid in order to make disbursements provided for in Articles 981 and 983 of this Code (including a disbursement not
subject to profit tax), as well as a disbursement taxed at source shall not be included in the costs under paragraph 1 of this article.
3. The following shall be subject to profit taxation:
a) payments made to purchase debt securities issued by a person registered in a country with preferential tax treatment, as well as
by a person exempt from profit tax under this Code (except for a budget organisation, the Legal Entity under Public Law – the
Deposit Insurance Agency and the National Bank of Georgia);
b) contractual penalties and/or other fines paid to a person registered in a country with preferential tax treatment, as well as to a
person exempt from profit tax under this Code (except for a budget organisation, the Legal Entity under Public Law – the Deposit
Insurance Agency and the National Bank of Georgia), which were incurred on the basis of contractual relations;
c) advance payments to a person registered in a country with preferential tax treatment, as well as to a person exempt from profit
tax under this Code (except for a budget organisation, the Legal Entity under Public Law – the Deposit Insurance Agency and the
National Bank of Georgia);
d) granting of a loan to a person registered in a country with preferential tax treatment, as well as to a person exempt from profit
tax under this Code (except for the Legal Entity under Public Law – the Deposit Insurance Agency and the National Bank of
Georgia) and/or payments made to purchase a claim against that person. This subparagraph shall not apply to transactions
conducted by a banking institution, credit union, microfinance organisation and loan provider with a person exempt from profit
tax under this Code;
e) loss incurred due to the transfer of the right to claim to and/or the denial of the right to claim for a person registered in a
country with preferential tax treatment, as well as a person exempt from profit tax under this Code (except for the Legal Entity
under Public Law – the Deposit Insurance Agency and the National Bank of Georgia);
f) a contribution made to the capital of a non-resident, as well as of a person exempt from profit tax under this Code, and/or a
payment made to purchase a share/equity (except for a share/equity placed on a foreign recognised stock exchange);
g) granting of a loan to a natural person or a non-resident (except for the purchase of loan securities placed on a foreign recognised
stock exchange). This subparagraph shall not apply to transactions conducted by a banking institution, credit union, microfinance
organisation and a loan provider;
g1) securing of a loan obtained by a partner natural person or a partner non-resident from a third person with the funds deposited
to a bank account. In such a case, the sum of an object of profit taxation shall be the amount of funds deposited to the bank
http://www.matsne.gov.ge 20000000005001016012
account for securing the loan. This sub-paragraph shall not apply to operations conducted by a banking institution, credit union,
microfinance organisation and a loan provider;
h) granting of a loan by a banking institution, credit union, microfinance organisation or a loan provider to a non-resident partner,
a partner exempt from profit tax under this Code or a partner natural person with at least 1 % of the capital participation, and/or
securing of a loan taken out by a partner from a third party with the funds deposited to a bank account. In such a case, the sum of
an object of profit taxation shall be the amount of funds deposited to the bank account for securing the loan.
4. Expenses related to the placement of shares and/or Global Depositary Receipts at stock exchange (including at the stock
exchange recognised by a foreign country), and to the issuing of such shares and/or Global Depositary Receipts, as well as expenses
related to changes made in the listing category/regime shall be considered as the expenses related to economic activity.
5. A country shall be considered as having preferential tax treatment if under the tax legislation of the country and/or separate
territories of the country:
a) a legal person is exempt from profit tax;
b) no profit tax is imposed on profit gained and/or distributed by a legal person, or the profit tax rate does not exceed 1/3 of the
profit tax rate existing in Georgia.
6. if, under the tax legislation of a foreign country or separate territories of a foreign country, either of the cases under paragraph 5
of this article takes place in relation to a legal person, this country and/or separate territories of the country shall, in this regard, be
considered as a country with preferential tax treatment.
7. If payment was effected (a sum was actually received) as a result of providing debt securities purchased or the right to
participate in the capital (shares/interest), or satisfying a demand, a person may set off and recover under the procedure established
by this Code a sum of the previously paid profit tax in the amount of a profit tax calculated according to the sum paid within the
accounting period of the actual receipt of the sum.
8. If a loan granted/advance payment was repaid, or goods/services were received in return for the advance payment, a person may
set off and recover under the procedure established by this Code a sum of the previously paid profit tax in the amount of a profit
tax calculated according to the sum repaid within the accounting period for repayment of the loan/advance payment or actual
receipt of the goods/services, or according to the amount of compensation for the goods/services received.
9. If securing of a loan by the funds deposited to a bank account is cancelled, a person may set off and recover under the procedure
established by this Code a sum of the previously paid profit tax in the amount of a profit tax calculated according to the security
with the funds deposited to the bank account cancelled during the accounting period of cancellation of the security.
10. The list of countries and/or separate territories of countries that are considered as countries with preferential tax treatment for
the purposes of this Code shall be compiled based on the criteria under paragraphs 5 and 6 of this article by ordinance of the
Government of Georgia.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 854 of 17 May 2017 – website, 2.6.2017
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 983 – Free delivery of goods/services and/or transfer of funds
1. For the purposes of this article, delivery of goods or services not intended to gain profit, income or compensation shall be
considered free delivery.
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2. Shortage in the inventory and/or assets provided for under this Code at the moment of its identification shall be considered as
free delivery of the good.
3. The following cases of free delivery of goods/services and/or transfer of funds shall not be subject to profit taxation:
a) a donation made to a charity organisation during a calendar year not exceeding 10 % of the net profit gained by the organisation
during a previous calendar year;
b) free delivery of goods, provision of services, or transfer of funds that are taxed at source under Article 154 of this Code;
c) free provision of hotel services (hotel accommodation) for not more than 60 days during a calendar year to a hotel room owner
by a tour company and/or a person/persons invited by a tour company under a contract for running/operating the hotel;
d) free delivery of goods, provision of services, and/or transfer of funds to the state, a municipality or a legal entity under public
law;
e) free provision of immovable property to a charitable organisation if the property recipient organisation does charitable work in
relation to persons with disabilities from childhood and/or persons with severe and persistent disabilities for at least three previous
calendar years;
f) free provision of a surety under Article 249 of this Code, a surety under the Civil Code of Georgia, and an easement;
g) free delivery of goods, provision of services, and/or transfer of funds to a person who is subject to profit taxation according to
the objects of taxation under Article 97(1) and (3) of this Code;
h) in accordance with the Law of Georgia on Reduction of Food Loss and Waste and on Food Donation, free supply (delivery) of
food by a participant of the food delivery chain to a charity organisation/a food bank.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 3549 of 4 October 2023 – website, 24.10.2023
Article 984 – Taxation of entertainment expenses
1. For the purposes of this article, entertainment expenses shall be defined under Article 8(33) of this Code.
2. For the purposes of Article 97 of this Code, the amount of entertainment expenses to be incurred during a calendar year shall be
limited to 1 % of the income gained during a previous calendar year, and to 1 % of the expenses incurred if the expenses exceed
the income gained.
3. The amount of entertainment expenses incurred during the calendar year of an enterprise establishment shall be limited to 1 %
of the expenses incurred before the end of the current calendar year.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Article 99 – Tax exemption
1. The following shall be exempt from profit tax:
a) (Deleted – 30.5.2018, No 2391);
b) (Deleted – 30.5.2018, No 2391);
c) (Deleted – 30.5.2018, No 2391);
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c1) (Deleted – 30.5.2018, No 2391);
d) profit from the sale of crosses, candles, icons, books and calendars used by the Patriarchate of Georgia for religious purposes;
e) profit earned by a person engaged in agricultural production from the primary supply of agricultural products made in Georgia
before their industrial processing (changing of commodity code) before 1 January 2018 or distribution of profit, and expenses
incurred/disbursements made within the scope of the same activity that are provided for in Article 97(1)(b-d) of this Code if the
income gained from such supply during a calendar year does not exceed GEL 200 000;
f) profit earned by an agricultural cooperative from a primary supply of agricultural products made in Georgia before their
industrial processing (changing their commodity code) before 1 January 2028 or distribution of profit, and expenses
incurred/disbursements made within the scope of the same activity that are provided for in Article 97(1)(b-d) of this Code;
g) (Deleted – 28.6.2019, No 4906);
h) (Deleted – 28.6.2019, No 4906);
i) (Deleted – 23.12.2017, No 1935);
j) income earned by a non-resident from a Georgian source based on the risk insurance and reinsurance by a company,
organisation and/or entrepreneur natural person;
k) income earned by non-residents from leasing out property that does not belong to the non-resident’s permanent establishment
in Georgia;
l) profit or distribution of profit earned from the sale of debt securities of the state, of the National Bank of Georgia, the Legal
Entity under Public Law – the Deposit Insurance Agency or of an international financial institution and profit in the form of
interests received from those securities, as well as profit or distribution of profit earned from the interest accrued on the funds
placed on the accounts with the National Bank of Georgia. The list of international financial institutions shall be determined by an
ordinance of the Government of Georgia;
l1) income earned by a non-resident as a result of supplying the loan securities issued by a resident legal person through a public
offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia, which does not
belong to the permanent establishment of the non-resident in Georgia;
l2) income earned by a non-resident as an interest from the loan securities issued before 1 January 2028 by a resident legal person
through a public offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia,
which does not belong to the permanent establishment of the non-resident in Georgia;
l3) income earned by a non-resident as a result of supplying the equity securities issued by a resident legal person through a public
offering in Georgia and allowed for trading on an organised market recognised by the National Bank of Georgia, which does not
belong to the permanent establishment of the non-resident in Georgia;
m) profit or distribution of profit earned by a FIZ Enterprise from business permitted within the Free Industrial Zone, and
expenses incurred/disbursements made within the scope of the same activity that are provided for in Article 97(1)(b-d) of this
Code;
n) (Deleted – 28.6.2019, No 4906);
o) (Deleted – 30.5.2018, No 2391);
p) profit (distribution of profit) earned from the supply of information technologies outside Georgia developed by a legal entity of
a virtual zone;
q) distribution of profit earned by a tourist zone entrepreneur from the delivery of hotel services up to 1 January 2026, and
expenses incurred/disbursements made within the scope of the same activity that are provided for in Article 97(1)(b-d) of this
Code;
r) distribution of profit received by a person organising a gambling club or a betting house from the said activity;
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s) distribution of profit earned by a special trading company from the conduct of permitted activities (except for the profit earned
by the company from the supply of a fixed asset used by the company for its economic activity for over two years);
t) (Deleted – 30.5.2018, No 2391);
u) distribution of profit earned by a person under the bankruptcy regime after opening of the bankruptcy regime under the
procedure established by the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors;
v) distribution of profit from compensation received in return for the property confiscated under Article 19 of the Constitution of
Georgia;
w) distribution of profit earned by a high-mountain settlement enterprise from an activity carried out in the same high-mountain
settlement, and expenses incurred/disbursements made within the scope of the same activity that are provided for in Article
97(1)(b-d) of this Code – for 10 years after being granted the relevant status (including the calendar year when the status was
granted);
x) distribution of profit gained from the interest earned from a financial institute certified under the legislation of Georgia;
y) distribution of profit earned by a person having the status of a special enterprise from an activity under Article 242(2)(a) and
(b) of this Code.
Note: a tax privilege under l1–l3 of this paragraph shall also apply when the loan/equity securities are allowed for trading on an
organised market before its recognition by the National Bank of Georgia. In addition, the privilege shall be effective from the date
of recognition of the organised market by the National Bank of Georgia.
2. For the purposes of this article, the types of hotel services (except for the hotel services under Article 8(33)(d.d) of this Code)
shall be determined by the Government of Georgia.
3. For the identification of the amount of profit exempt from profit tax under paragraph 1 of this article it shall be deemed that this
amount is to be paid first when a dividend is distributed by an enterprise.
Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 4961 of 24 June 2011 – website, 06.7.2011
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5452 of 9 December 2011 – website, 22.12.2011
Law of Georgia No 5791 of 13 March 2012 – website, 23.3.2012
Law of Georgia No 6053 of 24 April 2012 – website, 27.4.2012
Law of Georgia No 6015 of 10 April 2012 – website, 30. 4.2012
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 817 of 12 July 2013 – website, 05.8.2013
Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013
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Law of Georgia No 1046 of 6 September 2013 – website, 23.9.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4037 of 16 July 2015 – website, 28.7.2015
Law of Georgia No 5503 of 22 June 2016 – website, 12.7.2016
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 854 of 17 May 2017 – website, 2.6.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 2476 of 6 June 2018 – website, 21.6.2018
Law of Georgia No 3109 of 5 July 2018 – website, 11.7.2018
Law of Georgia No 3383 of 5 September 2018 – website, 24.9.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Chapter XIV – Gross income
Article 100 – Gross income
1. The gross income of a resident shall consist of the income earned from a source located in and outside Georgia.
2. A non-resident’s gross income shall consist of the income earned from a Georgian source.
3. Gross income shall be income earned in any form and/or through any activity, namely:
a) salary income;
b) income earned from economic activity, which is not related to employment;
c) other income not related to employment and economic activity.
4. The following shall not be included into the gross income:
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a) (Deleted – 13.5.2016, No 5092).
b) gratuitous transfer of goods and/or gratuitous provision of services to the State and/or the municipalities;
c) transfer of goods to other persons, within the framework of the projects (including the preparatory stage) provided for in the
international treaties ratified by the Parliament of Georgia, by legal persons under public law carrying out those projects and with
which the Ministry of Finance has signed an agreement on the implementation of the projects;
d) salary paid by a person having the status of a small business to a hired person, which, under Article 94(4)(a) of this Code, is not
taxed at source;
e) return of a fixed asset to a lessor in the cases provided for in Article 115(4)(b) of this Code;
f) benefit received by reducing taxes and/or sanctions (including a customs sanction) under a tax agreement made with a taxpayer,
writing off tax arrears, and by exempting from a tax sanction on the basis of Article 269(7) of this Code, or by exempting from a
customs sanction on the basis of Article 163(11) of the Customs Code of Georgia;
f1) benefit received by reducing the amount of fee and the related fine and surcharge on the basis of a tax agreement;
g) supply of agricultural produce made in Georgia as a result of agricultural activity between an agricultural cooperative and its
members (shareholders) and/or provision of services related to such activity before 1 January 2028;
h) market value of the immovable property (including land) supplied free of charge to a charitable organisation, if the organisation
receiving such property has been providing charitable activities for at least the last three calendar years to persons with a disability
from childhood and/or severe and persistent disabilities;
j) income earned by a tour company as a result of providing hotel services with the use of hotel assets/part of assets in possession of
a natural person (using them as hotel rooms/apartments) – for a natural person;
l) supply of the surplus energy produced by a retail consumer organisation, an owner of a micro power plant to a distribution
licensee.
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 817 of 12 July 2013 – website, 5.8.2013
Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 4088 of 22 July 2015 – website, 4.8.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 5491 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 3591 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
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Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 101 – Salary income
1. Salary income shall be any compensation or benefit received by a natural person as a result of employment, including income
earned as a pension or in any other form from the previous employment, or income from future employment.
2. For the purposes of the first paragraph of this article, the value of the benefit shall be the amount specified below which is
reduced by the amount paid by an employee to an employer at the time of receiving the benefit:
a) (Deleted – 28.6.2019, No 4906);
b) where an employer issues a loan to an employee at an interest rate lower than the rate fixed by the Minister of Finance of
Georgia – the amount corresponding to the interest payable at the interest rate fixed by the Minister of Finance of Georgia;
c) where an employer supplies, or gratuitously transfers, goods/services to an employee – the market price of such goods/services;
d) where an employer provides accommodation to an employee for use – the annual market value of the rental fee (in proportion
to the period concerned);
e) where an employer assists an employee or his/her dependants to receive education (not including a training program directly
related to the fulfilment of the employee’s obligations) – the value of the assistance rendered by the employer for the education;
f) where an employer reimburses an employee’s expenses – the amount of the reimbursement;
g) where an employer waives an employee’s debt or obligation – the amount of the debt or obligation, except when the expenses
for taking measures under the legislation of Georgia for enforcing payment of a monetary claim exceeds the amount of the
monetary claim.
h) where an employer pays an insurance premium or other amount for an employee’s life and health insurance – the amount of
the insurance premium or other amount paid by the employer;
h1) the volume of pension contributions made by an employer in favour of an employee to the pension scheme provided for by the
Law of Georgia on Voluntary Private Pension;
i) in other cases – the market value of the benefit under Article 18 of this Code.
21. The benefit gained by an employee as a result of using the employer’s motor car for his/her personal need shall be considered
as a salary and shall be subject to income tax, in the following amounts:
No Motor vehicle engine displacement Amount of income tax (in laris)
1 More than 3 500 cm3 300
2 2 500 – 3 500 cm3 200
3 Less than 2 500 cm 3 100
4 In case of a hybrid motor vehicle, any engine displacement 60
22. The reporting period for the income tax under paragraph 21 of this article shall be the calendar year, and it shall be paid by a
tax agent (employer) (except as provided for by Article 154(1)(a) of this Code) not later than the 15th day of a month following
the reporting month.
23. Use of an employer’s electric engine motor car by an employee for his/her personal need shall not be subject to income tax.
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24. The procedure for keeping record of an employer’s motor car used by an employee for his/her personal need and for
communicating information on such car to a tax authority shall be defined by an order of the Minister of Finance of Georgia.
3. Salary income shall not include:
a) reimbursement of business travel expenses paid to an employee within limits prescribed by the Ministry of Finance of Georgia;
b) reimbursement of entertainment expenses;
c) organised transportation of an employee from the place of residence to the place of work, or from the place of work to the place
of residence by an employer if this cannot be done with the use of public transport, or if an employee needs to incur unreasonable
expenses and/or spend unreasonable time to travel;
d) pension contributions made by an employer at its cost in favour of an employee, and by the State in favour of an employee, to
his/her individual pension account under the Law of Georgia on Funded Pension;
e) the benefit received as a result of payment of an insurance premium by an employer in favour of an employee within the
compulsory insurance in accordance with the legislation of Georgia;
f) transfer of accommodation for use and/or provision of food service and/or reimbursement of the expenses related to these
services by an employer to an employee if all the following conditions are met:
f.a) the accommodation/food is provided based on the specifics of an employer’s activity and it is a necessary condition for the
proper performance of obligations undertaken by an employee under an employment agreement, and/or provision of an employee
with a place of residence/food, without provision by an employer, requires payment of unreasonable expenses and/or spending of
unreasonable time by the employee;
f.b) the transfer of accommodation for use and/or provision of food service and/or reimbursement of the expenses related to these
services is not part of the labour remuneration provided for by an employment agreement between an employer and employees.
4. The amount specified in the second paragraph of this article shall include excise taxes, VAT and other taxes payable by an
employee.
5. For the purposes of paragraph 2(b) of this article, the interest rate shall be determined by the Minister of Finance of Georgia.
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 3308 of 21 July 2018 – website, 6.8.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3608 of 1 November 2023 – website, 20.11.2023
Article 102 – Income from economic activity
1. Income from economic activity shall be:
a) income from supplying goods/services;
b) surplus income from the sale of assets;
c) income received as a result of the restriction of economic activities or shutdown of an enterprise;
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d) amounts received from the sale of fixed assets; in the case of gratuitous supplying of fixed assets the market value shall be
included in the income under Article 111(7) of this Code;
e) reimbursed deductions under Article 146 of this Code;
f) interest income, except for the interest income received by a natural person from placement of the funds on deposits and time
deposits in banking institutions and other credit institutions;
g) dividends;
h) royalty;
i) benefit from writing off a person’s debt;
j) income from the transfer of property by leasing, easement, renting, letting or in any other similar form;
k) income from other economic activity.
2. Where goods/services are delivered free of charge, the market price of such goods/services shall be included in gross income.
This shall not apply to free dissemination of advertising goods, including through retail sellers, which have no independent
consumer specifications and are an integral part of the supply of the primary goods/services.
3. (Deleted – 13.5.2016, No 5092).
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 103 – Income not related to employment and economic activity
1. Income not related to employment and economic activity shall include any income or benefit, except for:
a) the contributions of partners increasing net assets of the enterprise in which they are partners;
b) according to an insurance contract:
b.a) the insurance compensation paid by an insurer to an insured natural person under a health insurance contract upon the
occurrence of an insured event;
b.b) the insurance compensation not exceeding the amount of the damage occurred, paid by an insurer to an insured natural
person under an insurance contract upon the occurrence of an insured event;
b1) the compensation, within powers delegated by the insurer, made by the Non-entrepreneurial (Non-commercial) Legal Person
– Compulsory Insurance Centre specified in the Law of Georgia on Compulsory Insurance of Civil Liability of Owner of Transport
Vehicle Registered in Foreign State and Moving within the Territory of Georgia for damage inflicted on the affected person (third
person) by the owner of an uninsured transport vehicle involving the transport vehicle, which does not exceed the amount of
damage occurred;
c) the value of goods and services purchased as test purchases under this Code and the legislation of Georgia, as well as income or
benefit secretly earned by a person who secretly assists criminal investigation authorities;
d) pension contributions made by the State in favour of a self-employed person to his/her individual pension account under the
Law of Georgia on Funded Pension;
e) the benefit received as a result of payment of an insurance premium by an employer in favour of an employee within the
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compulsory insurance in accordance with the legislation of Georgia.
2. If a person receives property or benefit from another person, the value of the property or benefit to be included in gross income
shall be determined under Article 101(2) of this Code.
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 3308 of 21 July 2018 – website, 6.8.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 3608 of 1 November 2023 – website, 20.11.2023
Article 104 – Georgian source income
1. For the purposes of this Section, Georgian source income shall be:
a) income earned from employment in Georgia;
b) income or benefit earned from the supply of goods in the territory of Georgia;
c) income earned from the delivery of services in Georgia. For this purpose, unless otherwise provided by this article, services shall
be deemed to be delivered in Georgia, if:
c.a) services are actually rendered in Georgia;
c.b) services are related directly to the immovable property located in Georgia;
c.c) services are related directly to the movable property located in Georgia;
c.d) services are related to the securities issued by a Georgian resident;
c.e) the place of actual delivery of services is Georgia and services are delivered in the sphere of culture, art, education, tourism,
recreation, physical culture and sports;
c.f) the delivery of services is related to transportation of cargo or passengers, and the place of commencement and ending of
transportation is Georgia;
c.g) a service provider and a service recipient are in different states and the service provider is a Georgian resident, except where
the service provider delivers services through its permanent establishment in another country that confirms the fact that the
service provider has delivered services in another country (other than in Georgia).
c.h) a service provider and a service recipient are in different states and the service provider delivers services in Georgia through
its permanent establishment to an employee or otherwise (at the same time, the expenses related to the delivery of services by the
service provider are incurred in Georgia irrespective of the place of actual payment of such expenses) that confirms the fact that
the service provider has delivered services in Georgia.
d) income earned from economic activity conducted in Georgia by a non-resident’s permanent establishment, including income
earned by a non-resident from the sale of identical (similar) goods in Georgia; as well as income from the services delivered in
Georgia, which are identical or similar to the services delivered by a permanent establishment;
e) income from the cancellation of obligations as a result of writing off bad debts related to economic activity conducted in
Georgia and income from the sale of fixed assets under Article 111(7) of this Code or income received as a result of compensation
under Article 146 of this Code;
f) dividends received from a resident legal person, or income earned from the sale of shares of a resident legal person and/or a
partner’s share in a legal person;
g) interest, provided the interest payer is a Georgian resident. At the same time, irrespective of whether the interest payer is a
Georgian resident:
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g.a) interest shall be deemed as a Georgian source income if a non-resident person has a permanent establishment in Georgia to
which the non-resident’s debt obligation is related and the interest expenses related to such debt obligation is attributed to the
expenses of the permanent establishment, irrespective of whether such expenses have been incurred by the permanent
establishment or not;
g.b) interest shall not be deemed as a Georgian source income if a resident person confirms that it has a permanent establishment
in a foreign country to which the resident’s debt obligation is related and the interest expenses related to such debt obligation is
attributed to the expenses of the permanent establishment, irrespective of whether such expense has been incurred by the
permanent establishment or not;
h) pension or scholarship paid by a resident;
i) royalty, if the payer of such royalty is a Georgia resident. At the same time, irrespective of whether the payer of the royalty is a
Georgia resident or not:
i.a) a royalty shall be deemed as Georgian source income if a non-resident person has a permanent establishment in Georgia with
respect to which the obligation to pay royalty arose, irrespective of whether such expense has been incurred by the permanent
establishment or not;
i.b) a royalty shall not be deemed as a Georgian source income if a resident confirms that it has a permanent establishment in a
foreign country with respect to which the obligation to pay royalty arose, irrespective of whether such expense has been incurred
by the permanent establishment or not;
j) income earned from the sale or assignment of rights existing or exercised in Georgia provided in Article 8(21) of this Code;
k) income earned from leasing movable property used in Georgia and/or from transferring any other contractual right of use;
l) income earned from immovable property located in Georgia and used for economic activity, including income from the sale of a
partner’s interest in such property;
m) income earned from the supply of shares of or partner’s interest in an enterprise, more than 50% of the value of which assets is
directly or indirectly created from the value of the immovable property located in Georgia;
n) income received from a resident enterprise or a non-resident’s permanent establishment in Georgia for management, as well as
financial and/or insurance services (including reinsurance services);
o) income earned in the form of insurance premiums under risk insurance or reinsurance contracts made in Georgia;
p) income earned from the provision of transport services in international carriage between Georgia and foreign countries or from
the provision of telecommunication services in international communication;
q) other income earned from carrying on activities in Georgia.
2. In determining the source of income specified in the first paragraph of this article, the place of receipt of the amount of income
shall not be taken into account.
3. (Deleted – 28.6.2019, No 4906).
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XV – Deductions and Loss
Article 105 – Expenses related to earning income
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1. All expenses related to earning income, other than the expenses that are not deductible under this Section, shall be deducted
from gross income.
2. Unless otherwise provided for by this Code, all expenses shall be documented.
3. The expense of purchase, installation and other capitalisable expenses of fixed assets shall be deducted on a phased basis as
depreciation charges, except where a taxpayer exercises the right to full deduction of depreciation charges.
4. A taxpayer may deduct from gross income:
a) benefit arising from supplying (including, free of charge) of goods/services to him/her, taking into account the restrictions
provided for by this Code, in the reporting year, in which such goods and services are used in economic activity;
b) the VAT amount assessed on goods with independent consumer specifications, disseminated gratuitously for advertising
purposes, unless a tax invoice has been issued with respect to the transaction.
c) costs related to the placement of shares and/or Global Depositary Receipts at stock exchange (including at the stock exchange
recognised by a foreign country) and to issuing such shares and/or Global Depositary Receipts, as well as expenses related to
changes made in the listing category/regime.
d) costs related to the income (profit) exempted from profit tax under Article 99(1)(l) of this Code.
5. The Minister of Finance of Georgia may determine:
a) certain cases where expenses need not be documented;
b) the list of documents that will be deemed as documents evidencing expenses notwithstanding the requirements of this Code.
6. (Deleted – 13.5.2016, No 5092).
7. (Deleted – 26.12.2013, No 1886).
8. (Deleted – 13.5.2016, No 5092).
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6330 of 25 May 2012 – website, 08.6.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 4720 of 24 December 2015 – website, 29.12.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Article 106 – Non-deductible expenses
The following expenses shall not be deducted from gross income:
a) expenses that are not related to economic activity, except for:
a.a) the case provided in Article 117 of this Code;
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a.b) the case where a legal person under public law supplies goods and/or provides services to the State and/or the municipalities
free of charge;
b) entertainment expenses, except where a taxpayer is engaged in the entertainment business and the expenses are incurred within
the framework of such business;
c) personal expenses of a natural person, expenses related to winnings from lotteries, casinos, gambling and other games of chance
or related to earning salary income;
d) expenses related to earning income that is exempt from profit or income tax, except as provided in the note to this article;
e) expenses incurred for goods/services that are not regarded as being supplied for the purposes of a profit tax, or during the supply
of which the corresponding income/market price is not included in the gross income under Article 100(4) of this Code, except as
provided in Article 100(4)(b) of this Code;
f) expenses incurred for goods/services purchased from a natural person having the status of a micro business, except when the
income received by a person having this status from the supply of goods/provision of services is taxed under regular procedures, or
when a consignment note/a document of a form determined by the Minister of Finance of Georgia is issued upon the
supply/purchase of goods;
g) (Deleted – 26.12.2013, No 1886)
h) expenses incurred with respect to the goods/services purchased from a flat tax payer within the scope of the activity subject to a
flat tax;
h) expenses incurred with respect to the goods/services purchased from a person having a status of a flat tax payer within the scope
of the activity (except for the activity taxable at a tax rate determined under Article 95 3 (1)(b) of this Code) subject to a flat tax
i) expenses of a person having the status of a flat tax payer not separated between the activity subject to a flat tax and additionally
performed activities.
Note: where so provided for in Article 82(1)(f) and (k) of this Code, a person may deduct expenses relating to the exempted
income. When using this right, a person shall apply income tax to the income exempt from income tax under Article 82(1)(f) and
(k) of this Code.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6330 of 25 May 2012 – website, 8.6.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2950 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 107 – Limiting interest deductions
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1. Taking into consideration the second paragraph of this article, interest paid and/or payable (under an accrual method) for a
credit (loan) shall be deducted within limits not higher than the annual interest rate set by the Minister of Finance of Georgia, in
proportion to the period concerned.
2. In an enterprise, more than 20% of the interest (shares) of which is directly or indirectly held by a legal person exempt from the
tax on profits, the maximum amount of interest deductible under the first paragraph of this article shall not exceed the total of any
interest income earned by a taxpayer and 50% of the total amount of taxable profit calculated without regard to interest income
earned and interest expenses incurred.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Article 108 – Deduction of bad debts
1. A taxpayer may deduct bad debts related to goods and service sold, where receivable income in previous reporting periods was
included in the gross income received from the economic activity.
2. Bad debts may be deducted only if tax arrears have been written off and recorded in the taxpayer's financial statements.
Article 109 – Deduction of allocations to reserve funds
A banking institution, a credit union, or a microfinance organisation shall deduct possible loan loss reserves from the gross income
according to the International Financial Reporting Standards (IFRS).
Note: for the purposes of this article, a credit (loan), overdraft, a letter of credit, a credit line, a guarantee and/or debt securities,
factoring, and any kind of preliminarily declared (fixed) income earned/to be earned from these instruments (including earned/to
be earned as a discount, interest, and/or a benefit) shall be considered a loan.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 2392 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 2441 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Article 110 – Deduction of scientific-research, design and development service expenses
Scientific-research, design and development service expenses related to the receipt of gross income shall be deductible, except for
the expenses related to fixed-asset purchases, installation and other capitalisable expenses.
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Article 111 – Depreciation charges and deductions according to fixed assets
1. The depreciation charges of fixed assets used for economic activity shall be deducted under this article.
2. Depreciation shall not be charged against land, works of art, museum exhibits, objects (other than buildings) of historical
significance, and other non-depreciable assets. At the same time, depreciation shall not be charged against a fixed asset and
biological asset with a value of up to GEL 1 000. A fixed asset with a value of up to GEL 1 000 shall be fully deducted from gross
income in the tax year in which it is put into service, and the expenses incurred for a biological asset shall be deducted from gross
income in the tax year in which they were actually incurred.
3. Fixed assets subject to depreciation shall be grouped according to the following depreciation rates:
Group Depreciation rate,
Fixed Assets
number %
Motor cars; motor and tractor equipment to be used on roads; office
furniture; motor transport rolling stock; trucks, buses, special vehicles and 20
1 trailers; machinery and equipment for all fields of industry, foundry
industry; forging and pressing equipment; construction equipment;
agricultural machinery and equipment.
2 20
Special instruments, fittings and equipment; computers, data processing
peripheral equipment and devices; electronic devices.
Railway, marine and internal land water vehicles; power machinery and 8
equipment; heating equipment, turbine equipment, electric motors and
3
diesel generators, power transmission and communication facilities;
pipelines.
4 Buildings, structures. 5
5 Depreciable assets not included in other groups. 15
4. The amount of depreciation charges for each group is calculated from the book value of a group at the end of a tax year in
accordance with the depreciation rates indicated in the third paragraph of this article.
5. Buildings and structures (‘buildings’) depreciation shall be charged against each building separately. Accordingly, each building
shall be regarded as a separate group.
6. The book value of a group at the end of a tax year shall be the amount calculated as follows: the book value of a group at the end
of a tax year preceding the reporting year:
a) shall be reduced:
a.a) by the depreciation amount charged in the tax year preceding the reporting year;
a.b) by the amount of deductions made under the eighth and ninth paragraphs of this article;
a.c) by the amount derived from the sale of fixed assets of a group during a reporting tax year, and in the event of gratuitous supply
of fixed assets, by market value;
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b) shall be increased:
b.a) by the value of fixed assets specified in Article 148 of this Code (other than non-depreciable fixed assets) added to the group in
the reporting tax year;
b.b) by the amount that exceeds the maximum limit for repair expenses incurred on fixed assets during a reporting tax year, in
accordance with Article 115(2) of this Code.
7. If the amount from the sale of fixed assets of a group during a tax year, and in the case of a gratuitous supply of fixed assets –
their market price, exceeds the book value of the group at the end of the year, the surplus amount shall be included into gross
income and the book value of the group shall be equal zero.
8. If the amount of the book value of a group at the end of the year is less than GEL 1 000, the amount of the book value of the
group shall be subject to deduction.
9. If all fixed assets of a group are sold or liquidated, the amount of the book value of the group shall be subject to deduction from
gross income.
10. Taxpayers may apply an accelerated depreciation rate to the second and third groups but the rate shall not exceed double the
amount of the respective rate provided for in the third paragraph of this article.
11. A non-entrepreneur natural person may not deduct depreciation charges against fixed assets used for economic activity.
12. Each fixed asset leased by a lessor shall be classified as a separate group. Depreciation charges for such assets shall be deducted
in the amount of discounted value of leasing fees that are calculated according to the leasing conditions and the book value of the
group of such fixed assets.
13. Where a leased fixed asset is returned to the lessor after expiry or termination of a lease contract, such fixed asset shall remain
in the same group and the deduction of depreciation charges against it shall be suspended pending its subsequent transfer by lease.
14. (Deleted – 26.12.2013, No 1886).
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3317 of 28 June 2023 – website, 18.7.2023
Article 112 – Full deduction of depreciation charges of fixed assets
1. A taxpayer may fully deduct the value of fixed assets, except for those contributed to the enterprise’s capital, in the tax year in
which the fixed assets are put into service.
2. If a taxpayer exercises the right of full deduction of the value of fixed assets, the taxpayer shall apply the same method in respect
of all subsequently purchased (manufactured) fixed assets.
3. When fully deducting the value of fixed assets:
a) the fixed assets shall not be included in the book value of the group provided for in Article 111;
b) the amounts received and/or receivable from subsequent supply of such assets, and in the absence of such amounts – market
value without VAT, shall be included in gross income.
4. If a taxpayer fully deducts the value of fixed assets, the taxpayer may not alter the chosen deduction rate for the next five years.
At the same time, the rate of deduction shall be chosen in the tax year in which the fixed assets are put into service.
http://www.matsne.gov.ge 20000000005001016012
5. The right of full deduction of the value of fixed assets shall not apply to non-depreciable fixed assets.
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Article 113 – Deduction of depreciation charges on intangible assets
1. The value of intangible assets shall be deducted in the form of depreciation charges, throughout their useful life, in proportion
to the reporting period. At the same time, a taxpayer may fully deduct an intangible asset with the value of up to GEL 1 000 from
gross income in the reporting year in which the relevant expenses were incurred.
2. If the useful life of intangible assets cannot be determined, the depreciation rate shall be 15%.
3. Each intangible asset shall be recorded in a separate group.
4. The value of amortisable intangible assets shall not include the expenses of purchase or manufacture of such assets if these
expenses were already deducted when calculating a taxpayer’s taxable profit (income).
5. If the amount of the book value of a group of intangible assets by the end of the year is less than GEL 1 000, the amount of the
book value of the group shall be deducted.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Article 114 – (Deleted)
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Article 115 – Deducting fixed asset repair expenses
1. Repair expenses of fixed assets in each group under Article 111(3) of this Code may be deducted annually up to 5% of the book
value of the group at the end of the tax year preceding the reporting year.
2. The amount exceeding the limit set by the first paragraph of this article shall increase the book value of the group concerned.
3. In exercising the right of full deduction of the value of fixed assets under Article 112 of this Code, repair expenses shall be
deducted in full, notwithstanding the limitation provided for in this article.
4. Repair expenses of fixed assets taken under lease, unless a contract provides for the reduction of rental charges in exchange for
the repairs, expenses shall be capitalised with the recipient of fixed assets and shall form by the end of the reporting period a
separate group. In that case:
a) expenses incurred shall be deducted from gross income according to the depreciation rates set by this Code for fixed assets at
15%;
b) if a fixed asset is returned to the lessor in the event of expiry or early termination of the contract, the book value of the group
shall be equal to zero and the remaining sum shall not be deducted from gross income. At the same time, the return of fixed assets
to the lessor shall not be regarded as supply.
5. (Deleted – 26.12.2013, No 1886).
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
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Article 116 – Limiting the deduction of entertainment expenses
Persons carrying on economic activity may deduct entertainment expenses up to a maximum of 1% of gross income received
during a tax year.
Article 117 – Deducting donations to charitable organisations
The amount donated by an enterprise/entrepreneur natural person to a charitable organisation shall be deducted from gross
income, also the market price of goods (other than immovable property)/services supplied free of charge and included into gross
income, but not more than 10% of the amount remaining after deductions under this Code from gross income (without the
deductions specified in this article).
Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013
Article 118 – Deducting insurance premium expenses
Insurance premiums paid and/or payable (using an accrual basis method) under an insurance contract by the policyholders and/or
the ensured in connection with economic activity, except for the insurance premiums paid by the insured under a pension
insurance contract, shall subject to deduction.
Article 119 – Expenses of the geological survey and preparatory services in connection with extraction of natural resources
1. Expenses of the geological survey and preparatory services in connection with extraction of natural resources shall be deducted
as depreciation charges from gross income according to the book value of the group at the depreciation rate of 20% under Article
111 of this Code, according to the book value of a group and shall be recorded as a separate group.
2. This article shall:
a) apply to the expenses on intangible assets incurred by a taxpayer for purchasing the right to geological survey, processing or
extraction of natural resources;
b) not extend to the intangible assets the useful life of which can be established and which can be deducted retain proportion to
the reporting period.
3. Expenses of the geological survey, preparatory services and drillings in connection with extraction of natural resources
performed under the production sharing agreement in accordance with the Law of Georgia on Oil and Gas shall be deducted
according to the rates provided by an agreement.
Article 120 – Non-deductible expenses and fines
1. The following shall not be deducted:
a) profit tax and income tax paid or payable in Georgia or in a foreign country, except for the income tax paid in connection with a
natural person’s earning of benefit (except for the benefit received from employment and economic activity). In that case, the
amount of the income tax payable for the income earned from the sale of property shall be reduced by the amount of the income
tax paid for this property (including in the preceding tax periods);
b) amounts of penalties/fines prescribed by the legislation of Georgia and paid or payable by a taxpayer to the budget.
2. (Deleted – 26.12.2013, No 1886).
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Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 121 – Carry-forward of losses
1. Losses incurred by an entrepreneur natural person upon sale of an asset (other than an asset used in economic activity) shall be
compensated by the surplus value resulting from the sale of an asset of the same type. If the losses cannot be compensated in the
same year, it shall not be carried forward to the next year.
2. Losses incurred by a natural person (other than an entrepreneur natural person) upon sale of an asset during a tax year shall be
compensated by the surplus value resulting from the sale of the asset of the same type. At the same time, if the loss cannot be
compensated in the same year, it shall not be carried forward to the next year.
3. The excess of deductions over the gross income from economic activity not related to employment, received by an entrepreneur
natural person shall not be deducted from the salary received by such person. It shall be carried forward for up to five years and
shall be covered by the excess of gross income of future periods over deductions not related to employment.
4. The excess of deductions over the gross income of a legal person shall be carried forward for up to five years and covered from
the excess of the gross income of future periods over deductions.
5. (Deleted – 28.6.2019, No 4906).
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 122 – Extension of the loss carry-forward period
1. A person may replace the 5-year loss carry-forward period specified in Article 121 of this Code with a 10-year loss carry-
forward period. For this purpose, the person shall apply to a tax authority before the expiry of the 5-year loss carry-forward period
specified in Article 121 of this Code.
2. In applying the provisions of the first paragraph of this article, a person, in the case of loss coverage, may change again the
chosen 10-year loss carry-forward period back to a 5-year loss carry-forward period. For this purpose, the person shall, in any tax
year following the loss coverage, notify a tax authority of reverting to a 5-year loss carry-forward period.
3. (Deleted – 18.12.2015, No 4680).
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Article 123 – (Deleted)
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Chapter XVI – International Taxation and Prevention of Tax Evasion
Article 124 – Setting off taxes paid outside Georgia
1. An enterprise (except for an enterprise under paragraph 2 of this article) may set off profit tax paid outside Georgia for a
respective tax year when paying tax on that profit in Georgia with respect to the income not earned from a Georgian source.
2. An enterprise subject to profit tax in the course of profit distribution may, when paying tax according to a dividend paid, set off
profit tax for a respective tax year, which is paid outside Georgia with respect to the income not earned from a Georgian source.
3. Amounts that are set off under paragraphs 1 and 2 of this article must not exceed the amounts of taxes that would be charged in
Georgia on that profit under the procedure and at the rates existing in Georgia.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Article 125 – Use of tax privileges by a non-resident under international agreements on prevention of double taxation
The procedure for granting tax privileges under international agreements on prevention of double taxation and for refunding to a
non-resident the taxes paid by the non-resident in Georgia shall be determined by an order of the Minister of Finance of Georgia.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Chapter XVII – Transfer Pricing
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 126 – Meaning of the concepts for the purposes of this Chapter
1. Two persons shall be related if:
a) one person directly or indirectly participates in the management, control or capital of the other person;
b) the same persons directly or indirectly participate in the management, control or capital of two persons.
2. A person directly or indirectly participates in the management, control or capital of an enterprise if:
a) he/she directly or indirectly owns over 50% of an enterprise;
b) he/she actually controls the business decisions of an enterprise.
3. Persons that are not related shall be independent.
4. Any transaction between related persons shall be a controlled transaction.
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5. Any transaction between independent persons shall be an uncontrolled transaction.
6. Margin is a rate of profitability calculated as the ratio of such indicators as purchases, sales, expenses and assets.
7. Transaction conditions shall mean the financial or other relevant indicators used in applying a transfer pricing method.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 127 – General principles of transfer pricing
1. For the purposes of this Code, where a Georgian enterprise performs one or several financial or commercial transactions with a
related enterprise, which is not a Georgian enterprise, each of such enterprises shall determine the amount of its profit in
accordance with the concept of an arm’s length transaction.
2. The amount of taxable profit of an enterprise performing one or several financial or commercial controlled transactions with a
related enterprise shall be in accordance with the concept of an arm’s length transaction, if the terms of the transaction do not
differ from the terms which would have been agreed upon if a comparable transaction had been performed between related
enterprises under comparable circumstances.
3. If the established terms of the transaction specified in the first paragraph of this article are not conducted as if it were at arm’s
length, any profits that would have accrued on one of the enterprises if the established terms of the transaction had been
conducted at arm’s length, but have not so accrued by reason of nonconformity with an arm’s length transaction, may be included
in the profits of that enterprise and taxed accordingly.
4. An uncontrolled transaction shall be comparable with a controlled transaction if:
a) there is no such significant difference between them that would have had any essential effect on the financial indicator that is
measured by a transfer pricing method;
b) in the case of the difference indicated in subparagraph (a) of this paragraph, for the purpose of eliminating the results of such
difference, a reasonably correct adjustment in the financial indicator of an uncontrolled transaction has been made.
5. Provisions of paragraph 3 of this article shall also apply to cases where a Georgian enterprise performs one or several financial or
commercial transactions with a resident of a country with preferential tax treatment, irrespective of whether they are related
persons or not. However, a transaction, one of the parties to which is a resident of a country with preferential tax treatment, shall
be considered as a controlled transaction.
6. The criteria, according to which the price of a transaction to be examined is deemed to be an arms-length price for the purposes
of this article, shall be determined by the Minister of Finance of Georgia.
7. The provisions of the third paragraph of this article shall also apply where a Georgian enterprise performs one or several
financial or commercial transactions with its permanent establishment.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Article 128 – Transfer pricing methods
1. The following transfer pricing methods shall apply to determine the conformity of the amount of taxable profit with the
concept of an arm’s length transaction:
a) Comparable Uncontrolled Price (CUP) Method. This method compares the price charged for property or services transferred in
http://www.matsne.gov.ge 20000000005001016012
a controlled transaction to the price charged for property or services transferred in a comparable uncontrolled transaction;
b) Resale Price Method. This method compares the margin arising from the sale in an uncontrolled transaction of goods purchased
in a controlled transaction with the margin arising from the sale in a comparable uncontrolled transaction of goods purchased in
comparable and uncontrolled transactions;
c) Cost Plus Method. Under this method, a cost plus mark-up that is added to the direct or indirect costs incurred for the supply of
goods or services in a controlled transaction is compared with the cost plus mark-up that is added to the direct or indirect costs
incurred for the supply of goods or services in a comparable uncontrolled transaction;
d) Transactional Net Margin Method. Under this method, the net profit margin obtained by an enterprise in a controlled
international transaction in relation to the appropriate indicator (e.g. sales, costs, assets) is compared to the net profit margin
obtained in a comparable uncontrolled transaction in relation to the appropriate indicators;
e) Transactional Profit Split Method. Under this method, a portion of the profit/loss received from the transaction, which an
independent enterprise would presumably have earned in a comparable uncontrolled transaction, is attributed to each enterprise
involved in the controlled transaction.
2. The arm’s length price of a controlled transaction shall be determined by the method that best suits each particular transfer
pricing instance.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Article 129 – Special provisions of transfer pricing
1. If so requested by a tax authority, a taxpayer shall provide an explanation as to why he/she believes that the profit earned by
him/her is in accordance with the concept of an arm’s length transaction defined by Article 127(1) of this Code. At the same time,
a taxpayer may provide sufficient information and analysis to back up his/her arguments and to verify the conformity of the
transactions performed by the taxpayer with related persons with Article 127(1) of this Code.
2. If the terms of an agreement concluded between an enterprise taxed in Georgia and its related enterprise is adjusted by a tax
authority of another country, as a result of which that country is to charge taxes on that portion of the profit that has already been
taxed in Georgia, and Georgia has signed a double taxation avoidance agreement with that country, then the Georgian tax
authority shall, based on the request from the Georgian taxpayer enterprise, verify whether the adjustment made is in accordance
with the concept of an arm’s length transaction. If the tax authority concludes that the aforesaid adjustment complies with the
concept of an arm’s length transaction, it shall make appropriate corrections and adjust the amount of tax of the Georgian taxpayer
enterprise.
3. Transfer pricing methods and their application, determination of comparability of uncontrolled transactions, transaction
adjustment procedure, information and documents to be submitted by the parties to a transaction to a tax authority, sources of
information on arms-length prices, price range application procedure, timeframes to be applied for the purposes of this Chapter
and other procedural matters shall be determined by an order of the Minister of Finance of Georgia.
4. Controlled transactions are examined in accordance with the provisions of this Chapter under the decision of the Head of the
Revenue Service.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 1291 – Advance pricing arrangement
1. Based on a taxpayer’s application, the Head of the Revenue Service may sign an advance pricing arrangement with the taxpayer
for purposes of this Chapter. An advance pricing arrangement is made before the commencement of a transaction, for a fixed
period of time; it determines a set of criteria for determining the transfer pricing for those transactions. Such criteria include
methods, comparable transactions and appropriate adjustments to them, as well as critical assumptions as to future transactions,
etc.
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2. An advance pricing arrangement shall apply only to the person in relation to whom it has been concluded. At the same time, an
advance pricing arrangement shall make a reference to the provision of the legislation of Georgia on which it is based.
3. If a person acts under an advance pricing arrangement, a controlling authority shall in no event make a decision or charge taxes
and/or penalties that contradict the advance pricing arrangement.
4. An advance pricing arrangement shall not apply if:
a) the facts and circumstances indicated in the advance pricing arrangement which would have affected the advance pricing
arrangement, do not correspond to the actual facts and circumstances;
b) the provision of the legislation of Georgia on which the advance pricing arrangement was based, has been abolished or
amended.
5. The provision of the legislation of Georgia that is unfavourable to a taxpayer and that has been given a retroactive force shall not
affect the transactions performed under an advance pricing arrangement signed before the provision took effect.
6. The information provided by a person for signing an advance pricing arrangement shall be treated as a tax secret.
7. If the price declared by a taxpayer is in accordance with the concept of an arm’s length transaction, the taxpayer shall not be
held liable under this Code just because he/she has violated a condition of the advance pricing arrangement referred to in the first
paragraph of this article.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Chapter XVIII – Taxation of Income at the Source
Article 130 – Taxation of dividends at the source
1. Dividends paid by a resident enterprise to a natural person, a non-entrepreneurial (non-commercial) legal entity or a non-
resident enterprise shall be taxed at source at the rate of 5% of the amount payable, unless otherwise provided for by this article.
2. Dividends received by the persons provided for by Article 2(3) of the Law of Georgia on Entrepreneurs (except for an individual
enterprise) shall not be taxed at the source and shall not be included in the gross income by an enterprise receiving the dividends.
3. Dividends received by a resident natural person that have been taxed at the source, shall not be included in the gross income of
that person and shall not be subject to further taxation.
31. (Deleted – 14.7.2020, No 6817).
4. (Deleted – 28.6.2019, No 4906).
41. Dividends received by a member of an agricultural cooperative from the cooperative before 1 January 2028 (except for the
dividends received from the profit earned from the activities provided for by Article 6(2) of the Law of Georgia on the Agricultural
Cooperative) shall not be taxed at source and shall not be included in the gross income by a person receiving the dividends.
5. (Deleted – 23.12.2017, No 1935).
6. Dividends paid to the State by a resident enterprise shall not be taxed at the source.
7. Dividends earned from a FIZ Enterprise in a Free Industrial Zone shall not be taxed at the source and shall not be included in
gross income by the person earning the dividends.
8. Dividends paid out by a banking institution, a credit union, a microfinance organisation or a loan provider from the profit
earned during 2023 and subsequent periods shall not be taxed at the source and shall not be included in the gross income by a
person earning the dividends.
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9. Dividends paid out from the profit earned during 2025 and subsequent periods shall not be taxed at the source and shall not be
included in the gross income by a person earning the dividends if that dividend has been paid out by an organiser of a slot machine
salon and/or an organiser of games of chance in a systemic and electronic form, who is subject to profit taxation at the rate
provided for by Article 98(6) of this Code, from the profit earned in this part of the activity.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Law of Georgia No 817 of 12 July 2013 – website, 5.8.2013
Law of Georgia No 5491 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5499 of 11 December 2019 – website, 23.12.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 134 of 13 December 2024 – website, 29.12.2024
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 131 – Taxation of interest at the source
1. Interests paid by a non-resident's permanent establishment or by a resident, or on their behalf to a natural person or to a non-
resident having no permanent establishment in Georgia shall be taxed at the source at the rate of 5% of the amount payable.
2. (Deleted – 30.6.2017, No 1182).
3. I Interest received by a natural person that have been taxed at the source shall not be included into the person’s gross income
and shall not be subject to further taxation.
4. (Deleted – 14.7.2020, No 6817).
5. Interest earned from a licensed financial institution in accordance with the legislation of Georgia shall not be taxed at the
source. At the same time, such interest shall not be included in gross income by the person earning the interest, unless the
recipient of the interest is a licensed financial institution.
6. (Deleted – 23.12.2017, No 1935).
7. Interest paid to the State by a resident enterprise shall not be taxed at the source.
8. Interest earned from debt securities issued by a Georgian enterprise and listed on a recognised stock exchange of a foreign
country shall not be taxed at the source and shall not be included in gross income by the person earning the interest.
9. Interest earned from a FIZ Enterprise in a Free Industrial Zone shall not be taxed at the source and shall not be included in gross
income by the person earning the interest.
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Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 132 – Taxation of royalty at the source
1. Royalty paid by a non-resident's permanent establishment or by a resident or on their behalf to a resident natural person (other
than the natural person registered as a VAT payer) shall be taxed at the source at the rate of 20% of the amount payable.
2. Royalty received by a natural person (except as provided for in the third paragraph of this article) that has been taxed at the
source shall not be included into the person’s gross income and shall not be subject to further taxation.
3. An entrepreneur natural person who has received royalty taxed at the source in Georgia may deduct the amount of the tax paid
at the source.
4. Royalty paid to the State shall not be taxed at source.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Article 133 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 1331 – (Deleted)
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 1332 – Taxation by a tourist enterprise of the income of a natural person who is the owner of the hotel assets/part of the
assets
1. Remuneration paid by a tourist enterprise to a natural person under a relevant contract shall be taxed at the rate of 5% of the
amount taxed at source.
2. In the case set out in paragraph 1 of this article, the income received by a natural person, which is taxed at source, shall not be
included in the gross income of the receiving person and shall not be subject to subsequent taxation.
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
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Article 1333 – Taxation of the income of a natural person supplying certain goods
1. The Minister of Finance of Georgia may define the list of goods by supplying of which the income earned by a natural person
shall be taxed at source at the rate of 3%, by a person purchasing the goods.
2. The procedure of taxing at source under paragraph 1 of this article shall apply if a consignment note is not prepared when
supplying goods.
3. The income earned by a natural person, which is taxed under this article, shall not be included in the gross income of the person
and shall not be subject to subsequent taxation.
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Article 134 – Taxation of a non-resident’s income at source
1. Income earned by a non-resident from a Georgian-based source that is not attributed to the non-resident's permanent
establishment registered for tax purposes in Georgia shall be taxed at the source without deductions at the following rates:
a) dividends – under Article 130 of this Code;
b) interests – under Article 131 of this Code;
b1) royalty – 5%;
c) amounts paid by an enterprise, organisation and/or entrepreneur natural person for international telecommunication services
and international transport services – at the rate of 10%.
d) income earned by non-resident subcontractors in conducting the oil and gas operations provided for by the Law of Georgia on
Oil and Gas – at the rate of 4%.
d1) lease service charges paid to a natural person – at the rate fixed by Article 81 of this Code.
e) other paid amounts, which under this Code are regarded as Georgian source income – at the rate of 10%;
f) salary income – at the rate fixed by Article 81 of this Code.
11. Income earned by a person registered in a country with a preferential tax treatment in cases provided for in paragraph 1(b), (b1
) and (e) of this article shall be taxed at source without deductions, at 15%.
2. For the purposes of this article, the taxes paid by or on behalf of a non-resident's permanent establishment in Georgia shall be
deemed as paid by a resident enterprise.
3. A non-resident who earns income under paragraph 1(c)-(e) of this article and is taxed at the source, may file a return by the 1
April of the year following the reporting year requesting recalculation and refund of withheld taxes.
4. If a person exercises the right under the third paragraph of this article:
a) Taxable income/profit of a non-resident shall be defined as a difference between the gross income gained from a Georgian
source and the amounts to be deducted under this Code;
b) (Deleted – 13.5.2016, No 5092);
c) taxes paid by a non-resident shall not exceed the amount withheld at the source under the first paragraph of this article.
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5. (Deleted – 13.5.2016, No 5092).
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Chapter XIX – Tax Accounting Rules
Article 135 – Accounting period
1. The accounting period for a person (except for persons provided for by paragraphs 2-5 of this article) shall be a calendar year.
2. The accounting period for a resident enterprise, organisation, and for a permanent establishment of a non-resident in Georgia
(persons subject to profit taxation according to objects of taxation under Article 97 (1-3) of this Code) shall be a calendar month.
3. The accounting period for a person, who is subject to income/profit taxation according to the object of taxation under Article
80(7 1), 97(9 3) or 309(16) of this Code, with regard to the organisation of betting house games in a systemic and electronic form,
shall be a calendar month.
4. The accounting period for an organiser of a slot machine salon and/or an organiser of games of chance in a systemic and
electronic form, shall be a calendar month.
5. The accounting period for assessing income tax on a surplus gained by a natural person through supplying property/assets
within non-commercial business activities shall be a calendar month.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Article 136 – Principles of accounting for income and expenses
1. A taxpayer shall accurately and timely account for income and expenses based on documented data by applying the methods
provided in this Chapter and attribute them to the reporting period in which they were earned or incurred.
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2. Unless otherwise provided in this Chapter, a taxpayer shall use a cash method of accounting or an accrual method of accounting
depending on which method he/she uses for accounting.
3. A taxpayer shall fully account for all transactions related to his/her activity in order to guarantee control over their
commencement, progress and completion.
4. In the case of transporting goods domestically for entrepreneurial activity, and in the case of supplying goods – at the request of
a buyer (except for supply carried out according to a Special VAT Invoice that contains the details found in a consignment note), a
consignment note shall be issued in the form and manner prescribed by the Minister of Finance of Georgia. At the same time, if a
consignment is issued at the request of a buyer for the supply of goods, the goods may not be stored without the consignment note.
41. The Minister of Finance of Georgia may determine cases where a consignment note is not issued.
5. Taxable income (profit) shall be determined by the same method that a taxpayer uses for accounting. At the same time, income
(profit) is adjusted only in compliance with the requirements of this Code. If the accounting data produced by a taxpayer
according to the deductions under this Code, and the limits provided for by this Code, differ, then the taxpayer shall apply the
norms under this Code to determine an object of taxation.
6. According to the provisions of this article, a taxpayer shall keep accounts for tax purposes on a cash basis or an accrual basis
provided that he/she uses one method throughout a tax year.
7. A natural person may account for income and expenses on a cash basis.
8. (Deleted – 14.7.2020, No 6817).
9. If a taxpayer changes any aspect of an accounting method, taxable income (profit) shall be adjusted in the year of such change,
provided that no element related to determining taxable income (profit) is omitted or included twice.
10. If a taxpayer earns income or incurs expenses in a non-cash form, the moment of earning such income or incurring such
expenses shall be determined in the same way as the moment of earning income or incurring expenses in cash form is determined.
11. The Minister of Finance of Georgia may require a taxpayer who conducts a certain type of activity, provided that different
taxation terms are provided for by this Code for such activity, to separately account for income and expenses related to that
activity. At the same time, income and expenses related to certain type of activity shall be evidenced by accounting documents.
12. A taxpayer may account for income and expenses in the manner prescribed by the Minister of Finance of Georgia.
13. Contractual penalties and other fines shall be accounted for on a cash basis.
14. The moment of incurring expenses and making other payments/disbursements under Articles 981 – 984 of this Code shall be
the very moment when they were actually incurred/made.
15. A person shall define and recognise the amounts of revenues and expenses within a derivative in compliance with
International Accounting Standards. In addition, the Minister of Finance of Georgia shall have the right to define individual cases
to which the aforementioned procedure for defining and recognising the amounts of revenues and expenses within a derivative,
and to regulate such cases in a different way.
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 137 – Accounting for income and expenses under a cash method
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In using a cash method of accounting, a taxpayer shall:
a) account for income upon obtaining the right to receive it or use and administer it;
b) deduct expenses after payment (this does not apply to fixed assets subject to depreciation under Article 111 of this Code).
Article 138 – Moment of earning income under the cash method
1. When using a cash method of accounting, the moment of earning income shall be:
a) if payment is made in cash – the moment of receiving cash;
b) in the case of non-cash settlement – the moment of transferring funds to a taxpayer's current account or to another account in a
banking institution, from which he/she may administer or draw those funds.
2. If a taxpayer's financial obligations are cancelled or covered, namely, in the case of a mutual set-off, the moment of earning
income shall be the moment of cancellation or coverage of the obligations.
Law of Georgia No 6312 of 25 May 2012 – website, 12.6.2012
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 139 – The moment of incurring expenses under the cash method
1. When using a cash method of accounting, the moment of incurring expenses shall be the moment when a taxpayer actually
incurs expenses, except as provided for in the third and fourth paragraphs of this article.
2. When using a cash method of accounting, the moment of incurring expenses by a taxpayer shall be:
a) if payment is made in cash – the moment when cash is paid;
b) in the case of non-cash settlement – the moment when a bank institution debits sums from a taxpayer's banking or another
account.
3. If financial obligations of a taxpayer are cancelled or covered, namely in the case of a mutual set-off, the moment of incurring
expenses shall be the moment of cancellation or coverage of those obligations.
4. In connection with debt obligations or payments related to leasing property, if the term of debt obligations or lease agreement
includes several reporting periods, the amount of actually paid interest (rent) that is deducted throughout a tax year shall be the
amount of interest (rent) that is calculated according to the amount charged or to be charged in each reporting period.
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 140 – Accounting for income and expenses under the accrual method
When using the accrual method of accounting, a taxpayer shall account for income and expenses according to the moment when
the right to earn the income is obtained and expenses are recognised, respectively, regardless of when income is actually earned or
expenses are actually incurred, except as provided for in Article 142(4) of this Code.
Article 141 – The moment of earning income under the accrual method
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1. A taxpayer shall be deemed to have obtained the right to earn income if:
a) the appropriate amount is subject to payment to the taxpayer;
b) the taxpayer has fulfilled all the obligations under a contract (agreement).
2. If a taxpayer provides services, the right indicated in the first paragraph of this article shall be deemed obtained at the moment
when the taxpayer completes the services under the contract (agreement).
3. If a taxpayer earns or has the right to earn income in the form of interest or from leasing property, the income shall be deemed
to have been obtained at the moment when the debt obligation or lease agreement expires. At the same time, if the term of the
debt obligation or lease agreement includes several reporting periods, income shall be apportioned to these reporting periods
according to the amount charged or to be charged in each reporting period.
4. (Deleted – 13.5.2016, No 5092).
5. A banking institution, a credit union or a microfinance organisation shall recognise the interest income accrued on loans
according to the International Financial Reporting Standards (IFRS).
Note: for the purpose of this paragraph:
a) a credit (loan), an overdraft, a letter of credit, a line of credit, an assurance and/or loan securities, factoring, and any kind of pre-
declared (established) income received/to be received from these instruments (including those received/to be received as a
discount, a commission and/or a benefit) shall be deemed a loan;
b) interest income shall be defined according to the International Financial Reporting Standards (IFRS).
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 2392 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 142 – The moment of incurring expenses under the accrual method
1. Unless otherwise provided for in this article, when using an accrual method of accounting, the moment of incurring expenses
related to a contract (agreement) shall be the moment when all the following conditions are fulfilled:
a) a taxpayer can be clearly deemed to have assumed a financial obligation;
b) the amount of the financial obligation may be assessed with sufficient accuracy;
c) all the parties to the contract (agreement) have actually fulfilled their obligations under the contract (agreement) and the
appropriate compensation is subject to necessary payment.
2. Financial obligations shall mean the obligations assumed under a contract (agreement) as a result of the fulfilment of which the
other party to the contract (agreement) shall indicate income corresponding to the obligation in cash or in any other form.
3. When interest on a debt obligation or rent for leased property is paid, the moment of incurring expenses shall be the moment
when the term of the debt obligation or lease agreement expires. If the term of a debt obligation or lease agreement includes
several reporting periods, the expenses shall be apportioned to the reporting periods according to their accrual.
4. Notwithstanding paragraphs (1-3) of this article, if a person, other than a licensed financial institution, uses an accrual method
of accounting, the moment of incurring expenses shall be the moment when the amount is paid, if:
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a) the payment is related to a natural person other than a natural person registered as a VAT payer;
b) the payment of the amount in compensation for services received is related to a non-resident enterprise that does not belong to
a non-resident’s permanent establishment in Georgia.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Article 143 – Joint ownership
1. The object of profit taxation of a partnership or other similar entity conducting economic activity and is deemed as an enterprise
under Article 21(1)(c) of this Code shall be defined under Article 97(1) of this Code.
2. A holder of an interest in a partnership shall include his/her share in the profit (its income) allocated to him/her from the
partnership in the gross income of a respective accounting period.
3. A partnership shall, under Article 154 of this Code, impose tax at source on the income distributed to a natural person (a person
who is not registered as an individual entrepreneur and/or a VAT payer) holding an interest in the partnership.
4. A member of a partnership may set off the tax withheld at source under paragraph 3 of this article against the amount of taxes
payable for the gross income earned during a year.
5. The losses of a partnership shall be attributed to its owners in proportion to their interests. At the same time, the losses of the
partnership shall not be distributed to its owners and shall not be deducted from owners’ gross income.
6. The portion of losses of an owner of a partnership may be deducted only at the expense of the owner’s share of the taxable profit
(of a future year/years) in the partnership. The losses shall be carried forward under the procedure established by Article 121(4) of
this Code.
7. The losses of a partnership attributed to its owner shall not be deducted from the profit received as a result of the owners’
participation in another partnership.
8. The delivery of goods/services by a partnership to its member in return for his/her interest shall not be deemed as a free delivery
of goods/services.
9. Provisions of paragraph 2 and paragraphs 5–7 of this article shall not apply to a member of a partnership, who is subject to profit
taxation according to the objects of taxation provided for in Article 97(1 – 3) of this Code.
10. Receipt of hotel assets/part of the assets by a tour company from a natural person under a relevant contract, use of the assets as
hotel rooms/apartments and organisation of the operation of the hotel shall not be regarded as a partnership under Article 21(1)(c)
of this Code.
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Article 144 – Income and deductions under long-term contracts
1. If a taxpayer keeps accounting under an accrual method, income and expenses from long-term contracts must be reported
throughout a tax year proportionately, according to their actual performance.
2. The volume of actual performance under long-term contracts shall be determined by comparing the expenses incurred by the
end of the tax year with the total expenses provided for by the contract.
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Article 145 – Accounting for inventories
1. A taxpayer shall include in its inventories finished or semi-finished goods in his/her ownership irrespective of their location,
namely, raw materials and/or materials (other than capitalisable expenses), which are purchased for subsequent sale or for
production of goods/delivery of services.
2. In determining taxable income (profit), the value of the inventory available at the beginning of a reporting period shall be
subtracted from, and the value of the inventory available at the end of the reporting period shall be added to, gross income.
3. When accounting for inventories, a taxpayer shall record the value of produced or purchased goods at the price of the expenses
(other than the depreciation charges) incurred during the production of these goods or at the purchase price of such goods. At the
same time, the taxpayer shall include the storage and transportation expenses in the value of the goods.
4. When selling goods, a taxpayer may apply one of the following methods to account for inventories:
a) specific identification method;
b) weighted-average method;
c) FIFO method, under which the goods purchased at the beginning of a reporting period are assumed to be the first item sold in
the reporting period, and the goods produced (purchased) during the reporting period are assumed to be the items sold later,
according to the time of their production (purchase).
5. When accounting for inventories, a taxpayer may evaluate defective or obsolete and outdated goods that cannot be sold at a
price higher than their production cost or purchase price, at an estimated selling price of such goods.
6. When writing off obsolete inventory items and/or items that are unfit for use or further supply, the taxpayer shall notify a tax
authority about the inventory write-off (indicating the types, quantity and value of the inventory) and write them off only in the
case of approval by the tax authority.
61. A tax payer may, without taking account of the conditions specified in paragraph 6 of this article, write off inventories
destroyed/lost as a result of the effect of force majeure events (earthquake, flooding, landslide, avalanche, fire, accident or another
emergency or extraordinary circumstance as a result of which inventories were destroyed/lost due to the reason independent of
the tax payer).
7. In the case provided for in the sixth paragraph of this article, when a taxpayer writes off inventories, a tax authority shall,
within 10 business days after receiving a taxpayer’s application, approve the write-off or perform a physical inspection of the
inventories by visiting the premises and endorsing the taxpayer’s write-off document.
8. In cases provided for in paragraphs 6 and 61 of this article, the procedure for writing off inventories shall be determined by the
Minister of Finance of Georgia.
9. A taxpayer may account for inventories electronically under the procedure determined by the Minister of Finance of Georgia.
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Article 146 – Reimbursed deductions and reduction of reserves
1. The amount of compensation for previously deducted expenses, losses and bad debts shall be reported as income in the year in
which it is received.
2. If the reserves deducted in advance are reduced, the reduced amount shall be included in gross income.
Article 147 – Profit and loss upon supply of assets
1. Profit earned from the supply of assets shall be a positive difference between the income earned from their supply and the value
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of those assets determined under Article 148 of this Code.
2. Loss incurred from the supply of assets shall be a negative difference between the income earned from their supply and the
value of those assets.
3. If assets are supplied free of charge or at a price lower than their cost, the supplier’s profit shall be a positive difference between
the market price of the supplied assets and the value of the assets specified in Article 148 of this Code.
4. Provisions of paragraphs (1–3) of this article shall not apply to assets and inventories subject to a group depreciation method.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Article 148 – Value of assets
1. Value of assets shall include their purchase, production, construction, assembly and installation expenses (costs) as well as other
expenses (costs) that increase their value, except for the expenses (costs) that may be directly deducted by a taxpayer, and in the
event of receiving assets free of charge, the market price of such assets.
2. If only a portion of assets is supplied or transferred, the value of the assets at the moment of supply or transfer shall be
apportioned between the remaining and the supplied or transferred portions.
3. If a fixed asset that was originally leased has been used for other purposes, its value shall be determined by the book value of the
group in which the fixed asset was previously recorded.
4. If, within a repo agreement, securities lending or financial collateral, a buyer/lendee supplies primarily purchased/supplied loan
securities to a third person, the value and the price of the supplied/redeemed loan securities shall be defined in each case by the
market price of the securities primarily supplied by a seller/lender.
5. An interest received by a buyer after purchasing loan securities, which is part of the purchase amount, must be considered as the
interest under Article 8(19)(b.d) of this Code, thus reducing the value of the securities. It shall not be included in the gross income
of the buyer.
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019
Article 149 – Non-recognition of profit or loss
1. In determining taxable income, no profit or loss shall be taken into account if:
a) assets are transferred between spouses;
b) assets are transferred between the former spouses at the time of dissolution of marriage;
c) assets are involuntarily destroyed/confiscated and if before the end of the next two years from the year in which the assets are
destroyed/confiscated:
c.a) the amount received as a compensation for the destruction/confiscation is reinvested into an asset of similar type and
character;
c.b) the destroyed/confiscated asset is replaced with an asset of similar type and character obtained as a result of compensation.
d) the registered shareholder of the resident company listed on/placed at a stock exchange of the foreign country in any form
(including in the form of Global Depositary Receipts) is changed without changing of the beneficiary shareholder;
e) within a repo agreement, securities lending or financial collateral, the loan securities are supplied and they or their other
equivalent loan securities are returned to the seller/lender at a pre-agreed price.
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2. The value of the replacement asset referred to in paragraph 1(c) of this article shall be determined by taking into account the
value of the replaced asset at the moment of the destruction/confiscation.
3. The value of the asset transferred under paragraph1 (a) and (b) of this article shall be the value of the given asset at the moment
of the transaction for the transferring party.
4. The provisions of this article shall not apply to the assets that are subject to a group depreciation method under Chapter XV of
this Code, except where all the assets of a group are transferred simultaneously under paragraph 1(a) and (b) of this Article.
Law of Georgia No 4720 of 24 December 2015 – website, 29.12.2015
Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019
Article 150 – Liquidation of legal persons
1. If a legal person is liquidated and a partner legal person receives assets in proportion (corresponding) to his/her interest and if
before the liquidation the partner legal person owned 50% or more in the given legal person, then:
a) such transfer shall not be regarded as the sale (supply) of assets by the liquidated legal person;
b) the value of the assets transferred to the partner in proportion (corresponding) to his/her share is the same as the value of the
asset before its transfer to the liquidated legal person;
c) distribution of assets shall not be regarded as a dividend;
d) profit and loss shall not be taken into consideration when cancelling the partner’s interest in the liquidated legal person.
2. The provisions of this article shall not apply to the assets that are subject to a group depreciation method under Chapter XV of
this Code, except where all the assets of a group classified according to one rate of depreciation are transferred simultaneously.
3. If all the assets of the group referred to in the second paragraph of this article, classified according to one rate of depreciation,
are transferred simultaneously, the value of the assets for the transferee shall be the book value of the group at the moment of the
transfer.
4. The first paragraph of this article shall not apply if:
a) a tax authority proves that the purpose of liquidation is tax evasion;
b) the partner legal person in the liquidation is a non-resident, except as provided for in paragraph 5 of this article.
5. If liquidation involves a non-resident partner legal person, the first paragraph of this article may be applied if, based on the
information produced by such person, a tax authority concludes that no tax evasion takes place and issues the appropriate consent.
6. Provisions of this article shall not apply if any party to a transaction is subject to profit taxation according to the objects of
taxation provided for in Article 97(1 and 3) of this Code.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Article 151 – Transfer of assets to a legal person in exchange for interest (shares) in that legal person
1. Transfer of assets (with or without liability) by a person(s) to a legal person in exchange for 50% or more interest (shares) in
such legal person shall not be regarded as supply of assets.
2. Where so provided for in the first paragraph of this article, the value of assets for the receiving party shall be the same as their
value for the supplier at the moment of transfer.
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3. The value of the partner’s interest received as a result of the exchange referred to in the first paragraph of this article shall be
equal to the value of the transferred assets minus the transferred (corresponding) liability.
4. The provisions of this article shall not apply to assets that are subject to a group depreciation method under Chapter XV of this
Code, except where all the assets of a group classified according to one rate of depreciation are transferred simultaneously.
5. If all the assets of the group classified according to one rate of depreciation referred to in the fourth paragraph of this article are
transferred simultaneously, the value of the assets for the transferee shall be the book value of the group at the moment of transfer.
6. The requirements of this article shall not apply to the transferor of assets with a legal defect if the liability exceeds the value of
the assets transferred.
7. Provisions of this article shall not apply if any party to a transaction is subject to profit taxation according to the objects of
taxation provided for in Article 97(1) and (3) of this Code, except for the case when a natural person transfers assets to a legal
person in return of 50 % or more equity/shares of the legal person.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 152 – Reorganisation of legal persons
1. The value of the property and interest (shares) owned by the legal person (persons) that is a party to a reorganisation shall be
equal to the value of such property or interest (shares) before the reorganisation.
2. The transfer of property or interest (shares) between legal persons that are parties to a reorganisation shall not be regarded as
sale of property.
3. Any exchange of an interest (shares) in a resident legal person that is a party to a reorganisation for an interest (shares) in any
other similar legal person, which is also a party to the reorganisation, shall not be regarded as sale of the interest (shares).
4. The value of the interest (shares) exchanged under the third paragraph of this article shall be equal to the original value of the
interest (shares).
5. Any distribution of an interest in a legal person that is a party to a reorganisation that gives rise to a similar right in any other
legal person, which is also a party to the reorganisation, shall not be regarded as a dividend.
6. The value of the original interest (shares) referred to in the fifth paragraph of this article shall be attributable to the distributable
interest (shares) at the ratio that is defined as the ratio between the market value of the distributed and original interest (stocks) at
the moment of distribution and the value of the original share after distribution.
7. If a tax authority fails to prove that the purpose of the operation of merger, acquisition, takeover or division is tax evasion, a
reorganisation shall involve:
a) the merger of two or more legal persons;
b) the acquisition or takeover of 50% or more of the interest and 50% or more of a partner’s interest in a resident legal person,
only with rights similar to those of the partners in an acquisition or takeover transactions, in exchange for an interest (shares);
c) acquisition of 50% or more of the assets of a resident legal person by another resident legal person in exchange for a voting
interest (shares), without preferential rights in relation to dividends;
d) division of a resident legal person into two or more resident legal persons.
8. A party to a reorganisation shall be any resident legal person:
a) that is directly involved in the reorganisation;
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b) that directly owns a resident legal person directly involved in the reorganisation;
c) that is owned by a resident legal person directly involved in the reorganisation.
9. For the purposes of the eighth paragraph of this article, the ownership of a legal person shall mean the ownership of 50% or
more of the voting interest (shares) in that legal person or the ownership of 50% or more of the value of all other remaining
interest (shares).
10. The provisions of this article shall not apply to assets that are subject to a group depreciation method under Chapter XV of this
Code, except where all the assets of a group classified according to one rate of depreciation are transferred simultaneously.
11. With respect to all the assets of the group classified according to one rate of depreciation referred to in the tenth paragraph of
this article, the value of the assets for the transferee shall be the book value of the group at the moment of transfer.
12. Provisions of this article shall not apply if any party to a transaction is subject to profit taxation according to the objects of
taxation provided for in Article 97(1 and 3) of this Code.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Chapter XX – Tax Administration Procedures
Article 153 – Filing tax returns
1. An income tax/profit tax return shall be filed with a tax authority by 1 April of a year following the reporting year by:
a) resident natural persons whose income is not taxed at a Georgian source (except for persons who are subject to income taxation
according to the objects of taxation provided for by Article 80(7) and 71 of this Code);
b) an enterprise (except for enterprises that are subject to profit taxation according to the objects of taxation under Article 97(1-3)
of this Code);
c) a non-resident natural person and a non-resident enterprise without a permanent establishment in Georgia if the income they
earn from a Georgian source is not taxed at source.
2. When terminating economic activity in Georgia, an entrepreneur natural person shall file with a tax authority a return of gross
income and deductions within 30 business days. At the same time, the taxpayer shall not be required to file tax returns in any
future period until the renewal of economic activity.
3. An entity in the process of winding up (a wound up company) shall, within 5 business days from the registration of
commencement of liquidation process, notify a tax authority in writing of the winding up and shall file a tax return with it within
the same period of time.
31. (Deleted – 1.5.2015, No 3581);
4. A natural person that is not obligated to submit tax returns may submit them to claim tax recalculation and refund.
41. (Deleted – 26.12.2014, No 3015).
5. An entrepreneur natural person, an enterprise and an organisation shall, not later than the 15th day of a month following the
accounting month, file a tax return to a tax authority on the amounts paid as remuneration, and taxes withheld during the
accounting month.
51. A taxpayer shall, within 15 days after entry into legal force of the ruling on recognising as admissible an application for
insolvency and on opening the bankruptcy regime delivered by the court under the procedure established by the Law of Georgia
on Rehabilitation and Collective Satisfaction of Creditors, submit to a tax authority:
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a) tax returns provided for in paragraph 1 of this article not submitted according to the complete/incomplete tax period (periods)
before opening of the bankruptcy regime. In addition, a taxpayer shall not submit an income/profit tax return according to the
complete/incomplete tax period (periods) after opening of the bankruptcy regime;
b) tax returns provided for in paragraph 5 of this article not submitted according to the complete/incomplete tax period (periods)
before opening of the bankruptcy regime. In addition, a taxpayer shall not submit a declaration on the amounts of remuneration of
labour paid out and taxes withheld according to the complete/incomplete tax period (periods) after opening of the bankruptcy
regime.
6. Before registering the title of a future owner, a registration authority shall notify a natural person about the obligation to report
and pay taxes, as well as about the liability for failure to fulfil such obligation:
a) where an asset owned by a natural person is sold;
b) where property is received as a gift (except where first and second line heirs receive property as a gift and where third and
fourth line heirs receive property with a value of up to GEL 150 000 as a gift and/or inheritance during a tax year);
c) where third and fourth line heirs receive property with a value of GEL 150 000 or more as a gift and/or inheritance during a tax
year.
7. If third and fourth line heirs receive property with a value of GEL 150 000 or more as a gift and/or inheritance during a tax year,
income tax shall be paid within not later than two calendar years. The timeframes for filing returns and paying taxes within the
two-year period shall be fixed by the Minister of Finance of Georgia.
8. The procedure for levying taxes on the remuneration paid to the citizens of Georgia by international organisations with
diplomatic status operating in Georgia shall be determined by the Minister of Finance of Georgia.
9. The procedure for levying taxes on the salary paid to the employees by a Free Industrial Zone Enterprise shall be determined by
the Government of Georgia.
10. An enterprise, an organisation and a permanent establishment of a non-resident enterprise (enterprises subject to profit
taxation according to the objects of taxation under Article 97(1-3), 91 and 93 of this Code) shall, on a monthly basis, not later than
the 15 th day of a month following the accounting month, file a tax return to a tax authority on the profit tax.
11. Natural persons who are subject to income taxation according to the objects of taxation provided for by Article 80(7) and 71
of this Code shall, on a monthly basis, not later than the 15th day of a month following the accounting month, file a tax return to
a tax authority on the income tax.
12. If a natural person gains a surplus through supplying property/assets within non-commercial business activities, he/she shall,
not later than the 15th day of a month following the accounting month, file a tax return to a tax authority on the income tax.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3015 of 26 December 2014 – website, 30.12.2014
Law of Georgia No 3581 of 1 May 2015 – website, 15.5.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Article 154 – Procedure for withholding tax at source
1. Tax shall be withheld at source by a tax agent who is a legal person, an enterprise/organisation or entrepreneur natural person,
namely:
a) a person paying salary to an employee, except for:
a.a) salary paid by a Free Industrial Zone Enterprise to a Georgian resident employee;
a.b) salary paid by a non-resident to an employee where such expenses are not attributed to the expenses of the non-resident’s
permanent establishment;
b) a person paying a pension to another person, other than the pension paid out within the state social security system;
c) a person paying taxes under Article 134(1) of this Code;
d) an enterprise/an organisation or an entrepreneur natural person, that pays the cost of rendered services to a natural person
(except for a natural person registered as a VAT payer, a notary officer, a private enforcement officer, a natural person having the
status of a micro/small business and a natural person having the status of a fixed tax payer, in the part of their activities) who is not
registered as an individual entrepreneur;
e) a person organising a promotional game, casino (with respect to organising a gambling tournament), a gambling club (with
respect to organising a gambling tournament), lotto, bingo, lottery who pays winnings to a natural person.
Note:
1. If a natural person wins, at his/her request, the person organising a casino, a gambling club or a betting house shall discharge the
tax agent’s obligations under this article with respect to the said activity;
2. This subparagraph shall not apply to the case provided for by subparagraph e 1) of this paragraph;
e1) an organiser of a slot machine salon and/or an organiser of games of chance and/or prize-winning games in a systemic and
electronic form (except for a promotional draw) who pays a sum to a player, including from the systemic and electronic gambling
account;
f) a person paying another person a scholarship, other than state scholarship;
g) a resident enterprise paying dividends to a person;
h) a person paying an interest to another person in the case provided for in Article 131 of this Code;
i) a person paying a royalty to a natural person;
j) (Deleted – 8.11.2011, No 5202).
k) a brokerage company provided for in Article 2(26) of the Law of Georgia on Securities Market, in the case of the sale of the
securities of a person that is not registered as a taxpayer, when paying the surplus income from the sale;
l) a person transferring property free of charge to a natural person that is not registered as an individual entrepreneur, except
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when this person transfers free of charge to the same natural person property with a value of up to GEL 1 000 during a tax year. In
such a case, the procedure for withholding a tax at source by a tax agent shall be determined by the Minister of Finance of Georgia;
m) (Deleted – 12.11.2025, No 1061);
n) a tourist enterprise – in the case set out in Article 1332 of this Code;
o) a person that pays a natural person the cost of goods purchased from him/her in the case provided for in Article 1333 of this
Code;
p) an asset management company, an insurer or a pension company – when paying to a participant of the pension scheme under
the Law of Georgia on Voluntary Private Pension the pension assets accrued on his/her personal pension account.
q) the Legal Entity under Public Law – the Pension Fund of Georgia – when passing/paying to an employee/a natural person under
the Law of Georgia on Funded Pension the pension assets being on his/her individual pension account.
2. When withholding taxes at the source:
a) the responsibility for withholding taxes and transferring them to the budget shall rest with the payer of income;
b) if the payer of income fails to withhold taxes, it shall transfer to the budget the amount of the tax not withheld according to
actually paid compensation along with the penalties related to it;
c) the recipient of income may pay the taxes and penalties on behalf of the payer of income.
3. The person withholding tax at the source under the first paragraph of this article shall:
a) transfer the tax to the budget upon paying an amount to a person, and when making non-monetary disbursements – on the last
day of the respective month;
b) when paying salary, at the request of the natural person receiving income, issue to that person a notice indicating the name and
surname of this person, the amount and type of income, as well as the amount of the tax withheld (if tax has been withheld);
c) submit a notice indicating the person’s registration number, name and surname, residential address, the total amount of income
and the total amount of tax withheld in the reporting period:
c.a) to a tax authority by not later than the 15th day of the month following the month in which the tax is withheld;
c.b) to the person who receives income upon request.
31. The Minister of Finance of Georgia may set for certain categories of taxpayers’ information submission timeframes different
from those prescribed by paragraph 3(c.a) of this article.
4. For each reporting period specified in Article 153(5) of this Code, by not later than the 15th day of the month following that
period, the tax agent referred to in the first paragraph of this article shall file with a tax authority a return on the performed
disbursements, in the form and manner prescribed by the Minister of Finance of Georgia.
5. To fulfil tax obligations with respect to the salary specified in paragraph 1(a.b) of this article, the employee may fulfil the
obligations regarding computing, reporting and paying taxes to the budget on his/her own in the manner prescribed by the
Minister of Finance of Georgia. In that case, a non-resident employer shall be released from the obligation to withhold tax at the
source.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5452 of 9 December 2011 – website, 22.12.2011
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6053 of 24 April 2012 – website, 27.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3608 of 1 November 2023 – website, 20.11.2023
Law of Georgia No 3903 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 3902 of 13 December 2023 – website, 25.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 4324 of 27 June 2024 – website, 12.7.2024
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 155 – Current taxes
1. An enterprise and an entrepreneur natural person, whose accounting period is a calendar year (with regard to the part of
activity for which the object of taxation is defined on the basis of a calendar year), shall make current tax payments to the budget
according to the annual tax payment of a previous tax year in the following amount:
a) not later than 15 May – 25%;
b) not later than 15 July – 25%;
c) not later than 15 September – 25%;
d) not later than 15 December – 25%.
2. A taxpayer who did not have any taxable income/profit during the last tax year or a person whose status of a micro business or
of a flat tax payer has been revoked in the current year and who had taxable income in the last tax year shall not pay current taxes.
3. If a taxpayer’s anticipated taxable income (profit) for the current tax year, taking into account tax privileges, decreases by at
least 50% compared with the last tax year’s income (profit) and the taxpayer notifies a tax authority about this before the due date
for the current taxes set by the first paragraph of this article, the taxpayer has the right to reduce or not to pay current taxes.
4. If a taxpayer applies the third paragraph of this article and if the presented actual annual results do not confirm the fact of at
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least 50% reduction of the anticipated taxable income (profit) and the taxpayer has not fully paid his/her current taxes in the
reporting year, he/she shall pay a penalty under this Code within the period from the dates fixed for the payment of current taxes
to the date of filing a tax return.
5. If a tax rate changes compared with the previous tax period, a taxpayer may pay current taxes from the amounts of the taxable
income (profit) of the previous taxable year recalculated at the rate applicable in the current taxable year.
51. (Deleted – 26.12.2013, No 1886).
6. The amounts of current taxes transferred to the budget shall be credited against the taxes assessed to the taxpayer according to a
tax year.
7. If current taxes are not paid, the tax enforcement measures under Article 238 of this Code shall apply.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
SECTION VI
VALUE-ADDED TAX
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Chapter XXI – General Part
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 156 – General provisions
1. This Section shall define the procedure for calculating and paying the value-added tax (the ‘VAT’).
2. The VAT is a tax set on the consumption of goods/services, which is directly proportional to the price of the goods/services.
3. The obligation to pay the VAT shall arise at all stages of supply of goods/provision of services, including the retail supply.
4. Where so provided for in this Section, the amount of VAT due can be reduced by the amount of VAT directly assigned to the
value of various components of charges related to the supply of goods/provision of services.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 157 – Definition of terms
The terms used for the purposes of this Section shall have the following meaning:
a) a person:
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a.a) a natural person;
a.b) an enterprise or an organisation under this Code;
a.c) an association of persons which independently participates in legal relations but does not have the status of legal person;
b) the place of establishment of a taxable person – a place from where a taxable person performs its main economic activities,
where the management body of the taxable person operates and the main decisions regarding its activities/management are made.
Note: if the criteria provided for in this subparagraph fail to precisely identify the place of establishment of the taxable person,
preference shall be given to the place where the main decisions regarding its activities/management are made;
c) the fixed establishment – any place which is not the place of establishment of a taxable person but is characterised by a
sufficient degree of consistence, and by a proper structure in terms of human and technical resources, thus allowing it to provide
or receive services and use them for its own need;
d) the permanent address – the address of a natural person where he/she has been registered under the procedure established by
the legislation, or the address of which a natural person has informed a tax authority, unless there is evidence that this address fails
to show the reality;
e) a place of residence – a place which a natural person has chosen as his/her ordinary residence, based on the personal
purpose/obligation or that of an economic activity, considering the close/stable connection to this place of residence of his/her;
f) the territory of Georgia – the territory defined by the legislation of Georgia, including the land space, its subsoil and air space
above it, internal waters and territorial sea, their bed, subsoil and air space above them, and the area adjacent to its territorial sea,
the special economic zone and the continental shelf, in relation to which Georgia can exercise its sovereign rights and/or
jurisdiction in accordance with international law;
g) public authorities – bodies that exercise the legislative, executive or judicial power, and the state supervision and control, in
accordance with the legislation of Georgia;
h) an immovable thing:
h.a) any place on or below the earth’s surface in relation to which the right of ownership or possession can arise;
h.b) any building/structure located on or below the earth, which is firmly linked to the earth and is not intended for temporary
use;
h.c) any thing which is an integral part of a building/structure and without which the building or structure is incomplete, in
particular a door, a window, a roof, a staircase, an elevator and other similar things;
h.d) any thing, equipment or machinery, which is permanently installed in a building/structure and which cannot be removed
without destroying or remaking it or without changing its intended purpose;
i) a gift of little value – goods or services that are transferred free of charge and the value of which, without VAT, does not exceed
GEL 50 during a calendar year, for one natural person. Advertisement and entertainment expenses shall not be considered a gift of
little value;
j) a trade agent – a taxable person whose main activity is to resell natural gas or electricity purchased, and whose consumed
volume of the aforementioned goods for personal purpose is insignificant;
k) an independently operable subdivision – part of the assets of a taxable person, which constitutes a combination of the
functionally interrelated fixed assets and the accompanying communications, and the independent operation of which does not
depend on the change of an owner;
l) an ancillary service/goods – a service/goods purchasing of which is not the main purpose of their customers but intend to ensure
improvement of the conditions for providing major services/supplying goods to them, and/or better usage;
m) a directly relating service/goods – a service/goods that are supplied to ensure supply of the main service/goods and which are
necessary to perform this main operation;
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n) a continuous service – a service the result of which can be used by a customer continuously, at any moment of the accounting
period;
o) a regular service – a service which is not a continuous service but it may be accepted by a customer at any specific moment of an
accounting period, based on a contract/agreement, without additional agreement with a service provider;
p) an electronically provided service – a service which is provided through internet or electronic network, supply of which is
essentially automated, requires minimum human interference and it cannot be provided without information technology;
including:
p.a) supply of digital products, including software support and supply of its updated version;
p.b) provision of websites;
p.c) webhosting, remote software and hardware maintenance;
p.d) software and the appropriate update;
p.e) provision of an image, text and information to ensure the accessibility of a database;
p.f) provision of music, films and games (including gambling games);
p.g) broadcasting and provision of political, cultural, arts, sports, scientific and entertainment programmes;
p.h) provision of distance learning;
p.i) other types of services defined by an order of the Minister of Finance of Georgia.
Note: the circumstance alone that the provider and buyer of services exchange information electronically does not in itself mean
that the service has been provided electronically.
q) the market price – the price that a customer would have to pay at an appropriate time when buying these goods or services at a
market of the same level where, under the conditions of free competition and economic independence of entities, the goods are
supplied or services are provided, and where this transaction is subject to VAT tax. If the comparable price of the goods or services
cannot be set, the market price, for VAT purpose, shall be:
q.a) for the goods – the price that must not be less than the purchase price for these or similar goods, and, where there is no
purchase price, the production cost of these goods at the time of their supply;
q.b) the services – the price that must not be less than the cost of all charges related to the provision of the services;
r) a voucher – an instrument that gives rise to an obligation of a taxable person to accept it as a remuneration or part of a
remuneration in return for the supply of goods/services, and the goods/services to be supplied or a potential supplier are
identifiable in it or in a related document, and the conditions for using this instrument;
s) a single-use voucher – a voucher upon issuance of which the place of supplying goods/providing services related thereto and the
VAT to be assessed in respect to this transaction is identifiable;
t) a multi-use voucher – a voucher that is not a single-use voucher;
u) a second-hand thing – a used movable thing, which is still suitable as is or after repair for usage, except for a piece of art, a
collectible item and antique, and for a precious metal or a precious stone, in the meaning defined by the legislation of Georgia;
v) a taxable dealer – any taxable person who, within economic activities, buys for further selling or uses for own economic
activities a second-hand thing, a piece of art, a collectible item or antique, or carries out the import of goods, irrespective of
whether he/she acts on behalf of himself/herself or another person, on the basis of a contract with him/her, according to which a
commission charge is payable when buying or selling goods;
w) NCNFEA – the National Commodity Nomenclature of Foreign Economic Activity;
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x) short term leasing of a vehicle – continuous possession or usage of a vehicle (of an air vehicle, ship and any other vehicle
provided for in Groups 86, 87, 88 and 89 of the NCNFEA), for not more than 90 days in the case of a ship, and for not more than
30 days in the case of another vehicle;
y) a tour operator – a person creating a tourist product and providing it to a tourist;
z) a tourist – a natural person to whom a tourist product is provided, for travelling in Georgia for at least 24 hours and for not more
than one year (including for recreation and/or health improvement purposes);
z1) a tourist product – a combination of at least two components of tourist service types (including transportation, accommodation,
food, tour guide service, and ancillary service for tourist services);
z2) repair of a fixed asset (building/structure) – modification (reconstruction) of the elements of a building/structure for the
purpose of prolonging their useful service and for ensuring enhancement of their capacity, except for current operating expenses
that are paid for the restoration or maintenance of the initial capacity of the fixed asset;
z3) investment gold – a gold bar or plate of not less than 995/1000 purity, and a golden coin made of gold of not less than 900/1000
purity, which is issued after 1800 and has been/was used as a means of monetary payment in the issuing country.
Note: additional criteria and procedure for establishing the status of investment gold, and the list of the golden coins that meet the
criteria for investment gold shall be defined by an order of the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 158 – A VAT taxable person
1. A VAT taxable person (the ‘taxable person’) shall be considered any person who, at any place, independently performs any type
of economic activity, irrespective of the purpose and result of the activity.
2. For the purposes of this Section, the following shall be considered an economic activities:
a) activities provided for by Article 2(2) and Article 3(1 and 2) of the Law of Georgia on Entrepreneurs;
b) activities of persons performing transactions of supplying goods/providing services, except for one-off/occasional activities,
based on paragraph 3 of this article;
c) use of property for earning regular income.
3. Despite the one-off/occasional nature, in any case, delivery of a non-residential building/structure shall be considered an
economic activity.
4. The following shall not be considered economic activities:
a) activities provided for by Article 9(2)(b-f) of this Code;
b) activities of a public authority/municipality body or of a legal person under public law if, when performing activities, it acts as a
state body (exercises powers delegated to it by the state), even when a membership fee and other fees, or another payment is
established for this activity, except for:
b.a) the telecommunication services;
b.b) the supply of water, gas, electricity or thermal energy;
b.c) the transportation of goods;
b.d) the port or airport services;
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b.e) the passenger transportation;
b.f) the supply of goods produced for selling purposes;
b.g) the supply of agricultural products and provision of services through an intermediary agency;
b.h) the organisation of the exhibition and sale;
b.i) the warehousing;
b.j) the advertising activities;
b.k) the activity of a tourist agent;
b.l) the food service;
b.m) the broadcasting and telecasting activities.
5. The Government of Georgia may, for avoiding the restriction of competition, define the types of activities different from
paragraph 4 of this article, and if and when they are performed, activities of a public authority/municipality body or of a legal
entity under public law shall be considered economic activities.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 884 of 2 August 2021 – website, 4.8.2021
Chapter XXII – Taxable Transactions
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 159 – VAT taxable transactions
1. The VAT taxable transactions shall be as follows:
a) the supply of goods by a taxable person within economic activity in the territory of Georgia, for consideration;
b) the provision of a service by a taxable person within economic activity in the territory of Georgia, for consideration;
c) the import of goods.
2. Supply of goods/provision of a service that is directly related to the supply of another type of goods/provision of another type of
services, or is of ancillary nature for the supply of another type of goods/provision of another type of services shall be considered as
part of the provision of this service/supply of these goods.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 160 – Supply of goods
1. Supply of goods shall be the transfer of the right of ownership of disposing of tangible property. The following shall also be
considered the supply of goods:
a) the transfer of the right of ownership of property, for consideration, by a decision of a public authority/municipality body,
and/or as provided for by the law;
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b) the factual transfer of goods under a rental, leasing or similar agreement, with the right of redemption;
c) the transfer of goods on the basis of an agreement according to which a commission fee is paid when buying or selling goods.
2. Electricity, gas, thermal energy, cooling energy and other similar property shall be considered as tangible property. Money
(except for a collectible item and/or a coin with numismatic value), and cryptography currencies (crypto assets) shall not be
considered as goods.
3. The following shall also be considered supply of goods for consideration:
a) the free supply of goods by a taxable person if its VAT on the goods or on the related charges has been fully or partially
deducted. In addition, the transfer/use of the goods as a sample or a gift of little value shall not be considered supply of goods for
consideration;
b) the use by a taxable person of a building/structure of own production as a fixed asset if it would not be able to fully receive the
VAT deduction in the case of purchasing the building/structure from another person.
Note: for the purpose of this subparagraph, own production shall mean construction of a building/structure on a plot of land
owned by/in possession of the taxable person by own efforts and/or by purchasing construction and installation services;
c) the supply of goods by a taxable person for personal use of its employees or the supply/use of goods for the purpose different
from the purpose of its own activity if its VAT on the goods or on the related charges has been fully or partially deducted;
d) the leaving of goods by a taxable person or its successor in title in its own possession after terminating economic activities if its
VAT on the goods or on the related charges has been fully or partially deducted;
e) the cancellation of the registration of a taxable person as a VAT payer if its VAT on the goods left on the balance sheet at the
time of cancellation of its registration as a VAT payer or on the related charges has been fully or partially deducted;
f) the transfer of goods by an enterprise or an association into ownership of a partner or a member of association respectively in
return for a share;
g) the expiry or early termination of the validity period of the status of a tourist enterprise;
h) the shortage provided for by this Code.
4. Supply by a co-owner of an immovable thing of his/her share in the co-ownership shall be considered supply of the immovable
thing.
5. If the right of ownership of an immovable thing has been registered on its purchaser in a registration authority with regard to a
facility under construction, the construction, installation and/or repair services provided by the supplier of the immovable thing
with respect to the supply of this thing shall be considered part of the supply of the immovable thing.
6. Joint supply of a land plot and the attached building/structure shall be considered supply of the building/structure.
7. The following shall not be considered supply of goods:
a) the supply by a taxable person of all assets or its part (independently operable subdivision) to another taxable person;
b) the contribution of an asset into the capital of an enterprise or partnership;
c) the transfer of an asset between persons – parties to the reorganisation of an enterprise.
Note: for the purpose of this paragraph, a person who has received the asset shall be considered a successor in title for the supplier
of this asset.
8. Conditions and procedure for the application of paragraph 7 of this article, and cases when the provisions under this paragraph
do not apply shall be defined by the Minister of Finance of Georgia.
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Article 1601 – Provision of services
1. Provision of services shall be any activity that is not supply of goods. The following shall also be considered provision of
services:
a) the transfer of intangible property;
b) the obligation to abstain from acting or to allow a specific act/situation;
c) the provision of services on the basis of a decision by a public authority/municipality body and/or as provided for by law.
2. The following shall also be considered provision of services for consideration:
a) the free provision of services by a taxable person for personal use of its employee or for the purpose different from the one of its
own activity;
b) the repair of own fixed asset (building/structure) carried out by a taxable person for the purpose of its activity if it would not be
able to fully receive the VAT deduction in the case of purchasing this service from another person.
Note: for the purpose of this subparagraph, the repair of the fixed asset (building/structure) shall be considered carried out by the
taxable person, whether by own efforts and/or through purchasing the repair services/works from a person who is not registered as
a VAT payer;
c) the provision of services by an enterprise or an association to a partner or a member of association respectively, in return for a
share.
3. A person who, on behalf of himself/herself but by order of another person, participates in the provision of services shall be
considered a beneficiary of the services and a provider of services.
4. The following shall not be considered provision of services:
a) the transactions provided for by Article 160(7) of this Code;
b) the transfer of the right of ownership of money, and of cryptography currency (crypto asset).
5. Provisions provided for by Article 160(7) of this Code, in cases defined by the same paragraph, shall also apply to the supply of
services.
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Article 1602 – Import of goods
The import of goods shall be the placement of goods under the Release for free circulation procedure under the Customs Code of
Georgia.
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Article 1603 – Transactions conducted through vouchers
1. The transfer of a single-use voucher to another person by a taxable person acting on its own behalf shall be considered the
voucher-related supply of goods or provision of services.
2. Where so provided for by paragraph 1 of this article, a factual supply of goods/services, in return for a single-use voucher, shall
not be considered an independent taxable transaction.
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3. The transfer of a single-use voucher by a taxable person acting on behalf of another taxable person shall be considered the
voucher-related supply of goods/provision of services carried out by the taxable person on behalf of whom this person acts.
4. If a taxable person, who carries out supply of goods/provision of services, is not a taxable person that has issued a single-use
voucher and who acts on its own behalf, it shall be considered that he/she has supplied the voucher-related goods/services to the
taxable person that has issued the voucher.
5. A factual supply of goods/services by a supplier in return for a multi-use voucher shall be considered a VAT taxable transaction.
In addition, all previous transfers of the multi-use voucher shall not be considered a VAT taxable transaction.
6. If transfer of a multi-use voucher is carried out by a taxable person who is not a person to carry out a taxable transaction
provided for by paragraph 5 of this article, provision of any service that can be defined as a service promoting the distribution/sales
of goods or a similar service shall be considered a VAT taxable transaction.
7. When goods/services are supplied continuously or regularly, in return for a voucher, VAT taxation shall be carried out for
taxation of the respective continuous/regular supply, at the moment defined under Article 163 of this Code.
8. The Minister of Finance of Georgia may define the procedure for taxing individual taxable transactions carried out through a
single-use voucher, which is different from the one in paragraphs 1-3 of this article.
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Article 161 – Reverse charge
1. The following shall be subject to VAT reverse charge:
a) provision of a service to a tax agent in the territory of Georgia by a taxable person who is not established or does not normally
live in Georgia, or who has no fixed establishment in Georgia which participates in providing this service;
b) transfer of a collateral (goods) to the possession of a creditor under a contractual obligation performance security measure;
c) foreign goods purchased from a person in the customs warehouse in the case provided for by Article 1641(4) of this Code,
which are placed under the Release for customs free circulation procedure;
d) in the case provided for by Article 1641(5) of this Code, foreign goods purchased from a FIZ enterprise, which are placed under
the Release for customs free circulation procedure.
2. For the purpose of this article, the following persons shall be considered tax agents:
a) for the purpose of paragraph (1)(a) of this article, any person established in Georgia (except for a non-entrepreneur natural
person and a FIZ enterprise), or which has a fixed establishment in Georgia through which the service was purchased;
b) for the purpose of paragraph (1)(b) of this article, a person (creditor) who takes possession of a collateral (goods) under a
contractual obligation performance security measure;
c) for the purpose of paragraph (1)(c) and (d) of this article, a person placing goods under the Release for customs free circulation
procedure.
3. Where so provided for by paragraph 1 of this article, a tax agent shall assess VAT:
a) where so provided for by paragraph (1)(a) of this article, on the sum to be paid for a service;
b) where so provided for by paragraph (1)(b) of this article, on the market price of a collateral (goods) taken into possession,
excluding VAT;
c) where so provided for by paragraph (1)(c) of this article:
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c.a) if the import and supply of goods are not VAT exempt, on the amount of a positive difference between the purchase value of
foreign goods in a customs warehouse and the amount of import of goods;
c.b) if the import of goods is VAT exempt and the supply of goods is VAT taxable, on the purchase value of foreign goods in a
customs warehouse;
d) where so provided for by paragraph (1)(d) of this article:
d.a) if the import and supply of goods are not VAT exempt, on the amount of a positive difference between the purchase value of
foreign goods from a FIZ enterprise and the amount of import of goods;
d.b) if the import of goods is VAT exempt and the supply of goods is VAT taxable, on the purchase value of foreign goods from a
FIZ enterprise.
4. Where so provided for by 1 paragraph of this article, the procedure for submitting a report by a tax agent to a tax authority and
paying the assessed tax to the budget shall be defined by the Minister of Finance of Georgia.
5. Where so provided for by paragraph (3)(b) of this article, the obligation of VAT assessment shall not be imposed on a person
registered as a VAT taxpayer. In addition, it shall be considered that he/she has received a VAT deduction of the appropriate
amount on the goods.
6. The following shall not be subject to VAT reverse charge:
a) the supply of goods or provision of services that are VAT exempt under this Code;
b) where so provided for by paragraph (1)(b) of this article, the transfer of a plot of land owned by a natural person and of a
flat/dwelling house attached to it.
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Article 1611 – VAT taxation in individual cases
1. Sale (supply) of goods by auction, direct sale or in another way, as part of a tax liability collection security measure or for any
other pecuniary liability (except for sanctions imposed under criminal and administrative procedures) shall be VAT taxable under
this article, and payment of the VAT assessed on this transaction on behalf of a person (the owner of goods) to the budget shall be
ensured by an authorised person carrying out sale of goods. In addition, in such a case, VAT shall not be charged on:
a) the supply of a flat/dwelling house;
b) the supply of a plot of land;
c) the supply of a car specified under the NCNFEA Code 8703 and/or a motorcycle (including a moped) specified under the
NCNFEA Code 8711;
d) the supply of property owned by a natural person (except for an individual entrepreneur).
2. Sale of insolvency mass by auction, direct sale or in another way under the procedure established by the Law of Georgia on
Rehabilitation and Collective Satisfaction of Creditors shall be VAT taxable under this article, and payment of the amount of VAT
assessed on this transaction on behalf of a person (the owner of insolvency mass) to the budget shall be ensured by an authorised
person selling the goods. In addition, except where insolvency mass is sold (supplied) as an integrated complex, VAT shall not be
charged on:
a) the supply of a flat/dwelling house owned by an individual entrepreneur;
b) the supply of a plot of land;
c) the supply of a motor vehicle;
d) the supply of agricultural machinery.
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3. Where so provided for by paragraphs 1 and 2 of this article:
a) the selling price of goods (the compensation paid/to be paid by the buyer) shall include the amount of VAT;
b) when VAT is charged on the supply of goods, Articles 170-172 of this Code, and other statutory provisions under this Code that
provide for the VAT exemption of the supply of goods, shall not apply.
4. The procedure for VAT taxation of the transactions under this article and payment of the VAT amount to the budget shall be
defined by an order of the Minister of Finance of Georgia.
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Article 1612 – Special taxation scheme for supply of certain goods
1. Supply of a second-hand thing, a piece of art, a collectible item or antique may be subject to VAT taxation according to the
special taxation scheme (‘the special scheme).
2. The profit margin of a taxable dealer shall be the difference between the supply price of goods and its purchase price.
3. The purchase price of goods imported by a taxable dealer, which must be taken into account when calculating the profit margin,
shall be the sum of the VAT taxable amount when importing the goods and the respective amount of VAT.
4. The VAT taxable amount following the supply of goods shall be obtained as a result of division of the amount of the profit
margin received by a taxable dealer by 1.18.
5. A taxable dealer shall not be entitled to have VAT deducted on the goods supply of which is subject to taxation under the
special scheme.
6. A taxable person shall be entitled to have VAT deducted with regard to the goods supplied or to be supplied to it by a taxable
dealer if the supply of the goods is subject to taxation under the special scheme.
7. A taxable dealer shall inform a tax authority about application of the special scheme provided for by this article, where a period
of application of the scheme shall be indicated, which may not be less than 24 months. The aforementioned period shall be
calculated from the beginning of a month the information under this paragraph was filed with the tax authority.
8. The procedure for applying the special scheme under this article and informing a tax authority about the application of the
scheme, and the types of pieces of art, collectible items and antiques supply of which may be subject to taxation according to the
special scheme shall be defined by the Minister of Finance of Georgia.
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Chapter XXIII – Place of Conducting Taxable Transactions
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Article 162 – Place of supply of goods
1. A place where the goods are located at the moment of their supply shall be considered the place of supply of goods, unless the
goods are dispatched or transported.
2. If goods are dispatched or transported, a place where the goods are located at the moment of starting to dispatch or transport
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them to the purchaser shall be considered the place of supply of goods.
3. If natural gas or electricity is supplied to a trade agent through the distribution network, a place where the trade agent has
established its activity, or where it has a fixed establishment for which the goods are supplied shall be considered the place of
supply of goods; and if there is no place of establishment of activity or fixed establishment, a place where the trade agent has
permanent address, or where it normally lives shall be considered the place of supply of goods.
4. When natural gas or electricity is supplied through the distribution network, unless it is provided for by paragraph 3 of this
article, a place of factual use and consumption of the goods by the consumer shall be considered the place of supply of goods.
5. If a consumer does not factually consume natural gas or electricity fully or partially, the goods that were not consumed shall be
deemed used and consumed at the place where the consumer conducts its activities or has a fixed establishment for which the
goods are supplied. If there is no place of activity or fixed establishment, it shall be deemed that the goods have been used and
consumed by the consumer at the place where he/she has permanent address, or where he/she normally lives.
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Article 1621 – Place of provision of services
1. If, under this article, services are provided within the territory of Georgia, it shall be deemed that they have not been provided
within the territory of another country, and if services are not provided within the territory of Georgia, they shall be considered as
having been provided within the territory of another country.
2. For the purpose of defining the place of provision of services, a person (except for a non-entrepreneur natural person) shall be
considered a taxable person in relation to any service provided to him/her/it.
3. Unless otherwise determined by this article:
a) the location where a service recipient is established shall be considered the place of provision of services, if the service recipient
is a taxable person. In addition, if services are provided for a fixed establishment of a service recipient, which is not located in the
place where the service recipient is established, the location of the fixed establishment shall be considered the place of provision of
services. If there is no place of establishment or fixed establishment, the location where the service recipient has permanent
address or where he/she/it normally lives shall be considered the place of provision of services;
b) the location where a service provider (taxable person) is established shall be considered the place of provision of services, if the
service recipient is not a taxable person. In addition, if services are provided by a fixed establishment of a service provider, which
is not located in the place where the service provider is established, the location of the fixed establishment shall be considered the
place of provision of services. If there is no place of establishment or fixed establishment, the location where the service provider
has permanent address or where he/she/it normally lives shall be considered the place of provision of services.
4. The place of provision of services related to an immovable thing shall be considered the place where the immovable thing is
located, including:
a) the services of an expert and an agent of immovable thing;
b) the services for the preparation and coordination of construction works (exercise of control and supervision on the construction
site).
5. The place of provision of a service provided to a non-taxable person by an intermediary acting on behalf and by order of another
person shall be considered the place of conducting a transaction for which the intermediary service has been provided.
6. For a non-taxable person, the place of cultural, art, scientific, education, entertainment, physical culture and sports or similar
events such as a performance, a presentation or an exhibition, and the place of provision of services for organising the above events
(including ancillary services) shall be considered the place where the events are actually carried out.
7. For a taxable person, the place of exercising the right of entry/access to cultural, art, scientific, education, entertainment,
physical culture and sports or similar events such as a performance, a presentation or an exhibition, and/or the place of provision
of ancillary services related to the above right of entry/access shall be considered the place where the events are actually carried
out.
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8. The place of provision of services shall be considered the location of its actual performance if any of the following services has
been provided to a non-taxable person:
a) the transportation-related services, which include loading, unloading, repacking, warehousing, and storage of goods during
carriage, packing of goods for transportation, preparation of documents before completion of custom clearance formalities,
inspection, check-up-related services and other similar services;
b) the assessment of a movable thing or the work/service related to such property.
9. The place of provision of transportation services to a passenger shall be considered the place where the transportation is carried
out, in proportion to the distance driven.
10. The place of provision of services of transportation of goods to a non-taxable person shall be considered the place where the
transportation is carried out, in proportion to the distance driven.
11. The place of provision of restaurant and/or food services shall be considered the place where the above services are actually
performed.
12. The place of provision of short-term vehicle lease services shall be considered the place where the vehicle is actually placed in
customer’s service.
13. The place of renting/leasing of a vehicle, except for short-term leasing, to a non-taxable person shall be the place where the
customer is established, has permanent address or normally lives. In addition, the place of rental of a leisure boat (except for short-
term leasing) to a non-taxable person shall be the place where the leisure boat is actually placed in customer’s service.
14. The place of provision of services to a non-taxable person shall be considered the place where he/she/it is established, has
permanent address or normally lives if any of the following services have been provided to him/her/it:
a) telecommunication services;
b) radio and TV broadcasting services;
c) electronically provided services;
d) the transfer or cession of a copyright, a patent, a licence, a trademark or other similar rights;
e) advertisement services;
f) consultancy, engineering, legal, accounting and other similar services, and data processing and information delivery service;
g) the obligation to abstain from full or partial performance or exercise of an economic activity or a right provided for by this
paragraph;
h) banking, financial and insurance transactions, including reinsurance, except for safe rental service;
i) personnel provision services;
j) leasing out of a movable thing, except for leasing of any type of vehicle.
15. The Minister of Finance of Georgia may define the cases when a certain service under paragraphs 3 and 12-14 of this article is
considered:
a) provided in another country if it is performed within the territory of Georgia, but the service is actually employed and/or used
outside the territory of Georgia;
b) provided in Georgia if it is performed outside the territory of Georgia, but the service is actually employed and/or used in
Georgia.
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Chapter XXIII1 – Time of Taxation
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Article 163 – Time of taxation when supplying goods/providing services
1. VAT taxation of supply of goods/provision of services shall be carried out at the moment of supplying goods/providing services,
unless otherwise provided for by this article.
2. If the sum is fully or partially paid before goods are supplied/ services are provided, payment of the respective VAT of the sum
paid shall be effected according to the accounting period for payment of the sum, except as provided for by paragraphs 5 and 9 of
this article.
3. a) a transaction provided for by Article 160(3)(b) of this Code shall be subject to VAT taxation at the moment when a taxable
person starts using its produced building/structure (fixed asset) in economic activities;
b) transactions provided for by Article 160(3)(d) and (e) of this Code shall be subject to VAT taxation at the moment when an
appropriate person terminates economic activities/cancels VAT registration;
c) transactions provided for by Article 160(3)(g) of this Code shall be subject to VAT taxation at the moment when the status of a
tourist enterprise is cancelled;
d) where so provided for by Article 160(3)(h) of this Code, VAT taxation shall be carried out at the moment when the shortage
under this Code is identified.
4. VAT taxation of a transaction provided for by Article 1601(2)(b) of this Code shall be carried out at the moment when repair of
the building/structure (fixed asset) is finished (the moment when provision of repair services/works would be VAT taxable if
performed by a person registered as a VAT taxpayer).
5. VAT taxation shall be carried out not later than the last day of each accounting period if telecommunication/communication
services are provided or goods (guaranteed capacity, electricity, gas, water, thermal energy, cooling energy or other similar goods)
are supplied regularly or continuously.
6. Unless the condition under paragraph 2 of this article is present, VAT taxation shall be carried out:
a) not later than the last day of each accounting period if services are provided regularly or continuously, considering paragraph 5
of this article;
b) except as provided for in Article 160(5) of this Code, when an immovable thing is supplied, at the moment of preparation of a
document confirming the right of ownership to be filed with a registration authority for the registration of the right of ownership,
and if the registration (transfer) of the right of ownership depends on the fulfilment of a certain obligation by a party (parties) to
this document and/or on the presence of the condition, then at the moment when such obligation is fulfilled/condition is present;
c) where so provided for by Article 160(1)(b) of this Code, at the moment when goods are actually transferred;
d) where so provided for by Article 160(5) of this Code, at the moment when an immovable thing is accepted into service.
7. Where so provided for by Article 161(1)(c) and (d) of this Code, VAT taxation of a respective transaction shall be carried out at
the moment when charging VAT on the import of goods.
8. Where so provided for in paragraph 5 of this article, if a taxable person keeps record of the supply of goods/services on different
days of an accounting period according to the amount of goods/services supplied during not a calendar month but during a certain
period (cycle) which may include the accounting period as well as a period preceding the accounting period, the amount of
goods/services recorded according to the different days of the accounting period (recorded according to the amount of
goods/services supplied during the certain period (cycle)) shall be considered supplied within the accounting period, irrespective of
the amount actually supplied within the accounting period.
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9. The Minister of Finance of Georgia may define cases of certain taxable transactions when paragraph 2 of this article does not
apply.
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Article 1631 – Time of taxation at import
VAT taxation of the import of goods shall be carried out in accordance with the customs legislation of Georgia at the moment
when customs obligations arise, and if the goods are not subject to import tax or are exempt from import tax, then at the moment
when the goods would be assessed unless they were exempt from this tax.
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Chapter XXIII2 – Taxable Amount
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Article 164 – Taxable amount when supplying goods/providing services
1. Unless otherwise provided for by this article, a VAT taxable amount shall be the compensation received/to be received in return
for the supply of goods/provision of services, without VAT, including the subsidy directly related to the price of the
goods/services. The aforementioned provision shall also apply to the case of goods/services exchange transaction (barter
transaction).
2. In cases provided for by:
a) Article 160(3)(a-e) of this Code, a VAT taxable amount shall be the purchase price of goods for the current or similar goods, or if
it does not exist, then their production price which, in appropriate cases, is set at the moment when goods are used, alienated,
converted (kept in possession) or when the registration as a VAT taxpayer is cancelled;
b) Article 160(3)(f) and (h) of this Code, a VAT taxable amount shall be the market price of goods, without VAT;
c) Article 160(3)(g) of this Code, a VAT taxable amount shall be the difference between the sum obtained as a result of division of
the turnover exempt from VAT under Article 172(4)(v) of this Code with the right of deduction by 1.18 and the declared sum of
the VAT taxable transactions (except for the VAT exempt transactions) as a result of functioning of the hotel (facility/its part) by a
person/persons invited for functioning/operation of a tourist enterprise and/or a hotel (including the sum additionally assessed by a
tax authority according to the aforementioned facility).
3. In cases provided for by:
a) Article 1601(2)(a) and (b) of this Code, a VAT taxable amount shall be the value of all expenses related to the provision of a
service;
b) Article 1601(2)(c) of this Code, a VAT taxable amount shall be the market price of a service.
4. A VAT taxable amount must include:
a) taxes, fees and dues, except for VAT;
b) related expenses, such as commission fees, or packing, transportation, and insurance costs charged by a supplier to a purchaser.
5. The following shall not be included in a VAT taxable amount:
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a) the discount for an advance payment;
b) the discount awarded to a purchaser of goods/services and obtained by him/her at the moment of supply, or another concession;
c) the amount received by a taxable person from a purchaser of goods/services as a compensation for the expenses borne on behalf
and by order of the purchaser. In addition, the taxable person shall have the obligation to prove the actual amount of expenses
specified in this subparagraph and he/she/it shall have no right to deduct the VAT paid in relation to the aforementioned;
d) the benefit under a leasing agreement – when goods are supplied under lease in the case provided for by Article 160(1)(b) of this
Code;
e) the sum of a penalty received/to be received with regard to the violation of a contractual obligation, or another kind of financial
compensation.
6. When goods/services under a multi-use voucher are supplied/provided, a VAT taxable amount shall be the compensation paid
for this voucher, without VAT. And if there is no information on the compensation, the VAT taxable amount shall be obtained as
a result of dividing the value specified in the multi-use voucher or the related documentation by 1.18.
7. When a taxable transaction is carried out between interdependent persons, a VAT taxable amount shall be the market price of
goods/services without VAT if:
a) the compensation amount of the taxable transaction is lower than its market price and the purchaser of the goods/services,
under this Code, has no right to fully deduct the VAT on this transaction;
b) the compensation amount of the taxable transaction is lower than its market price and the supplier of the goods/services, under
this Code, has no right to fully deduct the VAT and the supply is VAT exempt without the right of deduction;
c) the compensation amount of the taxable transaction is higher than its market price and the supplier of the goods/services has no
right to fully deduct the VAT.
8. Costs of multi-use (returnable) goods/tare shall not be included in a VAT taxable amount. In addition, if the aforementioned
goods were not returned, the VAT taxable amount shall be adjusted. The procedure for applying this paragraph shall be defined by
an order of the Minister of Finance of Georgia.
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Article 1641 – Taxable amount during customs procedures
1. A taxable amount when importing goods shall be the value of goods for customs purposes.
2. Unless a taxable amount contains the below components, the following shall be included in it:
a) taxes, fees or other dues, except for VAT, due in a foreign country and/or in Georgia, based on the import of goods;
b) related expenses, such as commission fees, or packing, transportation and insurance costs that are paid for transporting goods to
the first place of destination, and costs paid in the territory of Georgia for transporting goods to another place of destination if this
another place is known at the moment when the tax obligation arises.
Note: for the purpose of subparagraph b) of this paragraph, the first place of destination shall be the place indicated in the
document by which the goods are imported. In addition, if this place is not indicated in the appropriate document, the place of the
first transportation/transfer of goods in the territory of Georgia shall be considered the first place of destination.
3. The following shall not be included in a taxable amount:
a) the discount for an advance payment;
b) the discount awarded to a purchaser and obtained by him/her at the moment of import, or another concession.
4. When importing goods supplied to the customs warehouse, if:
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a) the import and supply of goods are not VAT exempt, the amount of VAT due at import shall be paid based on the amount of
import, and the amount of a positive difference between the value of purchasing foreign goods at the customs warehouse by the
importer and the amount of import of goods shall be subject to VAT reverse charge;
b) the import of goods is VAT exempt and the supply of goods is VAT taxable, the value of purchasing foreign goods at the customs
warehouse by the importer shall be subject to VAT reverse charge;
c) the import of goods is VAT taxable and the supply of goods is VAT exempt, the importer shall pay the amount of VAT due at
import based on the amount of import.
5. When a person imports goods purchased from a FIZ enterprise, if:
a) the import and supply of goods are not VAT exempt, the amount of VAT due at import shall be paid based on the amount of
import, and the amount of a positive difference between the value of purchasing foreign goods from a FIZ enterprise by the
importer and the amount of import of goods shall be subject to VAT reverse charge;
b) the import of goods is VAT exempt and the supply of goods is VAT taxable, the value of purchasing foreign goods from a FIZ
enterprise by the importer shall be subject to VAT reverse charge;
c) the import of goods is VAT taxable, and if the supply of goods is VAT exempt, the importer shall pay the amount of VAT due at
import based on the amount of import.
Note: where so provided for by this paragraph, obligations of the FIZ enterprise under this Code with regard to VAT, with regard
to the transaction of supplying goods to the importer shall be considered fulfilled.
6. Where so provided for by Article 54(2), (3) or (4) of the Customs Code of Georgia, the amount of import shall be defined in
accordance with the procedure established by the same paragraph for calculating the amount of import tax.
7. The export/re-export of goods shall be considered carried out if the goods are declared in the export procedure or when they are
re-exported, during which the export/re-export amount is the customs value of goods.
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Chapter XXIV – Registration of Taxable Persons
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Article 165 – Registration as a VAT taxpayer
1. A taxable person shall, unless otherwise provided for by this Code, from the day when he/she exceeds the total amount of GEL
100 000 for VAT taxable transactions of supplying goods/providing services carried out during any 12 consecutive calendar
months, within not later than 2 business days, apply to a tax authority for registration as a VAT taxpayer.
2. The obligation of a taxable person to calculate and pay the VAT shall arise from the moment of carrying out a taxable
transaction under paragraph 1 of this article (including this transaction), according to which the total amount of taxable
transactions has exceeded GEL 100 000.
3. A taxable person, who produces excisable goods in Georgia, shall apply to a tax authority for registration as a VAT taxpayer
before supplying the excisable goods.
4. A person set up as a result of reorganisation, if any party to the reorganisation is registered as a VAT taxpayer, shall apply to a
tax authority for registration as a VAT taxpayer before carrying out a VAT taxable transaction provided for by paragraph 1 of this
article, but not later than 10 days after completion of the reorganisation.
5. If an enterprise/partnership accepts goods/services as a contribution from a partner/member registered as a VAT taxpayer, the
enterprise/partnership shall apply to a tax authority for registration as a VAT taxpayer before carrying out a VAT taxable
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transaction provided for by paragraph 1 of this article, but not later than 10 days after making the contribution.
6. A person may voluntarily get registered as a VAT taxpayer. In such a case, he/she shall be considered a VAT taxpayer from the
day of applying to the tax authority, but not later than the period allowed for compulsory registration.
7. When defining the total amount of VAT taxable transactions provided for by paragraph 1 of this article, the taxable transactions
exempt from VAT under this Code shall not be taken into account, except for:
a) the transactions exempt from VAT under this Code that are related to a financial or immovable thing if carrying them out is the
main activity of the taxable person;
b) the export transactions of goods;
c) the transactions exempt from VAT under Article 172(1) and (2) of this Code.
71. When defining the obligation for registration as a VAT tax payer for a person with the status of fixed tax payer, the income
gained from a fixed taxable activity shall not be considered.
8. When defining the total amount of VAT taxable transactions provided for by paragraph 1 of this article, for a person set up as a
result of reorganisation, the VAT taxable transactions of the parties to reorganisation shall be taken into account, under the
procedure established by this article.
9. Irrespective of the requirements of paragraphs 1 and 2 of this article, the obligation of a taxable person, who has a fixed
establishment in Georgia, to calculate and pay the VAT shall arise from the moment of providing services/supplying goods
(including this transaction), and he/she shall apply to a tax authority for registration as a VAT taxpayer not later than the last day
of the accounting period for carrying out this transaction.
10. The procedure for registering VAT taxpayers shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 1651 – Cancellation of registration as a VAT taxpayer
1. If the total amount, without VAT, of taxable transactions (except for the transactions that are VAT exempt under this Code,
based on Article 165(7) of this Code) provided for by Article 165(1) of this Code carried out by a person during the last 12 calendar
months does not exceed GEL 100 000 and one year has passed from the date when he/she was last registered as a VAT taxpayer,
he/she can apply to a tax authority for the cancellation of his/her registration as a VAT taxpayer.
2. With the consent of a person, a tax authority may, irrespective of the requirements of paragraph 1 of this article, at its own
discretion, cancel the registration of this person as a VAT taxpayer. The procedure for applying this paragraph shall be defined by
an order of the Minister of Finance of Georgia.
3. The registration as a VAT tax payer shall be cancelled:
a) upon liquidation of an enterprise/organisation – from the date when the registration was cancelled in the state/entrepreneurial
register;
b) when a person dies – from the date of his/her death;
c) when a person makes an application for or consents to a cancellation of VAT registration from the first day of the month
following the written application/consent of the person;
d) upon opening of the bankruptcy regime under the procedure established by the Law of Georgia on Rehabilitation and
Collective Satisfaction of Creditors – from the publication of the court ruling on recognising as admissible of an application for
insolvency and on opening the bankruptcy regime.
4. The procedure for cancelling registration as a VAT taxpayer shall be defined by an order of the Minister of Finance of Georgia.
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Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 1652 – Persons liable for VAT payment
1. The obligation to calculate and pay VAT shall arise for a person registered or liable for registration as a VAT taxpayer, except as
provided for by paragraph 2 of this article.
2. Without liability for registration as a VAT taxpayer, the obligation to calculate and pay VAT shall arise for:
a) a person importing goods;
b) a tax agent, for a transaction subject to reverse charge under this Code;
c) a person authorised to sell goods, when selling the goods, within a measure for insuring payment of a tax liability or for the
purpose of enforcing payment of another pecuniary liability (except for a sanction imposed under criminal and administrative
procedure), by auction, direct sales or another way;
d) a person selling the goods, when selling insolvency mass under the procedure established by the Law of Georgia on
Rehabilitation and Collective Satisfaction of Creditors;
e) a taxable person who is not established or does not normally live in Georgia, or who has no fixed establishment which
participates in the provision of services, if the place of provision of services by him/her/it is Georgia under this Code and this
transaction is not subject to reverse charge. The procedures for fulfilling the obligation defined by this subparagraph and for
informing the taxable person shall be defined by an order of the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Chapter XXIV 1 – VAT Rate, Tax Period and Reporting
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 166 – VAT rate
The VAT rate shall be 18%.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 167 – Tax period
The VAT accounting period shall be a calendar month.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
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Article 168 – Declaration procedure
1. A taxable person registered as a VAT taxpayer shall submit to a tax authority a VAT declaration not later than the 15th day of
the month following the accounting period and shall pay the tax within the same period.
2. When importing goods, the amount of VAT shall be paid in accordance with the procedure established for payment of the
import tax, except as provided for by paragraph 3 of this article.
3. The VAT assessed when importing goods provided in the list defined by the Government of Georgia and specified under the
NCNFEA codes 8401-9033 shall be paid not later than 45 days after releasing the goods for free circulation.
4. Where so provided for by this Code, when a transaction is subject to reverse charge, a tax agent (except for a person registered
as a VAT taxpayer) shall pay the assessed amount of VAT under the procedure established by the Minister of Finance of Georgia,
not later than the 15th day of the month following the accounting period.
5. A person registered as a VAT taxpayer shall, within a period of 15 days after entry into legal force of the ruling on recognising as
admissible of an application for insolvency and on opening the bankruptcy regime delivered by the court under the procedure
established by the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors, submit to a tax authority the
appropriate not-submitted declarations for the complete/incomplete tax period (periods) before commencement of the bankruptcy
regime.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Chapter XXV – VAT Exemption
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 169 – General provisions
1. This Chapter shall define cases of VAT exemption of taxable transactions.
2. Taxable transactions provided for by Articles 170 and 171 of this Code shall be VAT exempt without the right of VAT deduction
meaning that if these transactions are carried out, the taxable persons shall have no right to deduct the VAT, in relation to the
charges borne with regard to the transactions.
3. Taxable transactions provided for by Articles 172 of this Code shall be VAT exempt with the right of VAT deduction meaning
that if these transactions are carried out, the taxable persons shall have the right to deduct the VAT in relation to the charges
borne with regard to the transactions, under the procedure established by this Code.
4. Joint supply of goods and/or provision of services that are VAT taxable and VAT exempt shall be considered as separate VAT
taxable and VAT exempt transactions of the supply of goods and/or provision of services, except for the supply of the main
goods/provision of the main services together with the supply/provision of the directly related goods/services.
5. A taxable person shall have the right not to enjoy a tax privilege under this Code and charge the transactions provided for in
Article 171(1)(a) and (c) of this Code with VAT. The procedure for applying this paragraph shall be defined by an order of the
Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 170 – Privileges in the fields of medicine, education, culture, sport and social services
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1. The following shall be VAT exempt without the right of deduction:
a) inpatient/outpatient medical service/care and provision/supply of the directly related and/or ancillary services/goods by a person
who has the right to perform medical activities under the legislation of Georgia;
b) provision of medical services by a person who has the right to perform medical and/or paramedical activities;
c) provision of services by a dental technician within his/her professional activity, and provision of dental prosthetics services by a
dentist and/or dental technician;
d) provision of a transportation service to a sick or injured person in a vehicle specially designed for this purpose;
e) provision of educational services by an educational institution, and provision/supply of a directly related and/or ancillary
service/goods;
f) provision by a tutor of schooling and university education services performed by an educational institution;
g) provision of art education and sports training services to a natural person under 18 years of age, and provision by an
organisation of services directly related to sports and/or physical training/education to a person who performs the aforementioned
activity;
h) supply of goods/provision of services directly related to the social security of the population (including provision of childcare
services at a fostering institution, an early education institution, and/or a pre-school educational institution, or provision of care
services to sick persons, persons with disabilities and/or persons over 60 years of age, or supply of goods/provision of services to an
elderly shelter);
i) provision of services/supply of goods directly related to the protection of child and adolescent rights, by the guardianship and
custodianship authority defined by the legislation of Georgia;
j) provision of services by an organisation, proceeding from the purpose of its activity, in return for membership fees set for its
own members, and supply of directly related goods;
k) performance of restoration, rehabilitation, designing and research works on the monuments of cultural heritage included in the
World Heritage List and which are of the category of national importance and/or which have a ceremonial and religious purpose,
in agreement with the Ministry of Culture of Georgia;
l) delivery of personnel provision services by a religious organisation for the performance of any activity provided for by
subparagraphs a), e), h) and i) of this paragraph;
m) provision of services/supply of goods by an organisation whose activity is exempt on the basis of any subparagraph out of
subparagraphs a), e) and g-k) of this paragraph, within measures arranged for raising funding only for the purpose of its activity;
n) universal postal services performed within the power delegated by the state, except for the passenger carriage/transportation
service and the supply of goods in relation thereto. The list of universal postal services shall be defined by an ordinance of the
Government of Georgia;
o) supply by the postal operator appointed by the state of the national postage (postage stamp) under the legislation of Georgia by
its nominal value;
p) provision of ceremonial services (including a vehicle service) related to a funeral;
q) supply of diabetic bread, which is labelled as such at the time of supply;
r) supply by the Patriarchate of Georgia of crosses, candles, icons, books, calendars and other liturgical items used only for a
religious purpose;
s) restoration and/or painting of cathedrals or church buildings.
2. The Minister of Finance of Georgia may define the procedure and criteria for applying the tax privileges provided for by
paragraph 1 of this article.
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Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 342 of 16 March 2021 – website, 18.3.2021
Law of Georgia No 3829 of 30 November 2023 – website, 15.12.2023
Law of Georgia No 109 of 12 December 2024 – website, 28.12.2024
Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025
Article 171 – VAT exemption of certain category transactions without the right of deduction
1. The following shall be VAT exempt without the right of deduction:
a) financial transactions/financial services;
b) provision of services with lotteries, gambling and games of chance, except for the service provided for by Article 172(4)(r) of
this article;
c) supply of a plot of land;
d) supply of a plot of land and an apartment/dwelling house to a natural person if the supplier supplies this property to a natural
person or a first line heir of a natural person:
d.a) from whom he/she has received this property within the measure for securing performance of his/her and/or another natural
person’s contractual obligation;
d.b) whose property he/she has purchased by auction or another way for enforcing payment of his/her and/or another natural
person’s financial liability;
e) provision of lecture courses through electronic media (disks), which are of educational nature and may also be published in the
form of a book;
f) provision of selling services and printing services of goods (magazines, newspapers and printed music) specified under the
NCNFEA Codes 4901, 4902 and 4904 00 000 00, and/or provision of advertising services by newspapers and magazines;
g) supply of the property transferred to state ownership, and transfer (supply) of property on lease under the Law of Georgia on
State Property;
h) supply of the state property (except for movable property transferred to state ownership) on the basis of privatisation
programme;
i) supply of a partnership interest (the right of preliminary registration of title to property) if no property is attached/personified to
that interest (right), except where property is transferred into ownership in return for the interest (right);
j) lease of the goods supply of which is VAT exempt without the right of deduction, under this Code;
k) provision of services by passenger vehicles (except for taxis) with regulated prices and rates on urban and intraregional routes;
l) provision of sweeping and cleaning, and waste management services for a municipality on a populated territory;
m) provision of mandatory stamping/marking services of excisable and/or non-excisable goods by a person selected by the Revenue
Service under the procedure established by the legislation of Georgia;
n) supply by a natural person of hotel assets provided for by Article 261(1) of this Code/part thereof owned by him/her if a new
owner (natural person) takes over the previous owner in a contractual relationship between the previous owner and the tourist
enterprise;
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o) supply (distribution) by a partnership of property to its member (co-owner) if the members of the partnership are only natural
persons, the composition of members of the partnership has not changed from the foundation of the partnership till the moment
of transfer (distribution) of property and the partnership is not a VAT taxpayer at the moment of distribution. For the purpose of
this subparagraph, when a member of partnership dies, transfer of the partnership interest to his/her heir or sale of the interest of
the member of partnership under the Law of Georgia on Enforcement Proceedings shall not be considered a change in the
composition of the members of partnership;
p) supply of goods specified under the NCNFEA code 4820 20 000 00;
q) supply of goods by a FIZ enterprise to another FIZ enterprise;
r) provision of services by a FIZ enterprise to another enterprise of the same FIZ;
s) supply of goods originated or manufactured in an occupied territory of Georgia from the occupied territory of Georgia to a
person having the status of special enterprise;
t) provision of construction and installation, repair, restoration, research and development and/or geological survey services
financed with soft loans for the rehabilitation of the electricity sector issued by the foreign states and/or international
organisations under international agreements of Georgia ratified by the Parliament of Georgia;
u) provision of services on the basis of an agreement funded by a foreign organisation for the liquidation of a natural disaster,
accident and catastrophe, with the aim of humanitarian aid, and to which an appropriate executive authority of Georgia is a party;
v) supply of goods and/or provision of services related to the equipment and machinery, vehicles, spare parts and materials
intended for performing oil and gas operations under the Law of Georgia on Oil and Gas, and for performing operations related to
oil and gas for investors and operating companies under agreements provided by the aforementioned Law and/or under licenses
granted for performing oil and gas operations;
w) supply of goods provided for by Article 173(a-n) of this Code;
x) provision of easement services free of charge.
2. Supply by a taxable person of the goods that are used by him/her for any activity exempt from VAT under Article 170(1) of this
Code or paragraph 1(a) and (b) of this article if the right of VAT deduction has not arisen and/or has not been applied at the time
of purchasing the goods shall be VAT exempt without the right of deduction.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1024 of 11 November 2025 – website, 14.11.2025
Article 172 – VAT exemption with the right of deduction
1. Supply/provision of the following goods/services shall be VAT exempt with the right of deduction:
a) supply of goods in high sea, or for chargeable passenger carriage, or for commercial, industrial or fishing activities, or for rescue
or aid-at-sea operations, or for the provision of a vessel intended for off-shore fishing with fuel or food;
b) supply of goods for the provision of a battleship specified under the NCNFEA Code 8906 10 00 with fuel or food, which leaves
the territory of Georgia;
c) supply, remaking, repair, maintenance, freight or lease of a vessel provided for by subparagraph 1 of this article and supply,
lease, repair or maintenance of an equipment installed or used on such vessel;
d) apart from services provided for by paragraph 1(c) of this article, provision of other services for immediate need of a vessel
under paragraph 1(a) of this article or its cargo;
e) supply of an aircraft with fuel or food;
f) supply, remaking, repair, maintenance or lease of an aircraft, and supply, lease, repair or maintenance of an equipment installed
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or used on such aircraft;
g) apart from services provided for by paragraph 1(e) of this article, provision of other services for immediate need of a craft under
paragraph 1(f) of this article or its cargo;
h) carriage of goods placed under export, re-export, outward processing or transit, or intended for transit (which is confirmed by
the documents accompanying goods), and provision of services directly related to the carriage. The services directly related to such
carriage shall be as follows:
h.a) during carriage, services related to sending/receiving of cargo and/or vehicles and means of carriage, and services provided by
airports, harbours, railway or vehicle stations/terminals;
h.b) air or sea navigation, dispatching and/or information services;
h.c) forwarding services;
h.d) preparation of cargo documents, inspection, examination, transportation processing (including loading and unloading)
services, and packing for transportation and storing services;
h.e) agenting services in harbours;
i) provision of passenger and baggage carriage services and of services directly related to the carriage, provided that a point of
departure or destination is located outside of Georgia and that a unified transport document has been drawn up for such carriage.
Services directly related to such carriage shall be as follows:
i.a) services related to sending/receiving of passengers and/or vehicles, and services provided by airports, harbours, and railway
and vehicle terminals;
i.b) air or sea navigation, dispatching and/or information services, and supervision of aero navigation services;
i.c) inspection, examination, transportation processing (including loading and unloading) services, and packing for transportation
and storing services;
i.d) passenger ticket sale services for international passenger transportation;
i.e.) passenger services within customs control zones at airports and harbours, the cost of which is included in the price of a
passenger ticket of the international transportation;
i.f) agenting services at harbours.
2. Provision of services by an intermediary acting on behalf of another person shall be VAT exempt with the right of deduction, in
the case of participation in the transactions provided for by paragraph 1 of this article or in the transactions carried out outside of
Georgia.
3. Supply of goods and/or provision of services shall be VAT exempt with the right of deduction if they are intended for the official
use by a foreign diplomatic mission or an equivalent representation or for private use by a member of the representation or
diplomatic mission (including the family members living with him/her). The procedure for applying the tax privilege under this
paragraph shall be defined by the Minister of Finance of Georgia.
4. The following shall also be VAT exempt with the right of deduction:
a) supply of natural gas to thermal power stations;
b) supply of assets by an enterprise over 50% of interest/shares of which is owned by the state and/or a municipality to the state
and/or the municipality by withdrawing them from the capital;
c) transfer of goods and/or provision of services to the state and/or a municipality free of charge;
d) transfer of goods by legal entities under public law that implement projects (including of preparatory stage) defined by the
international agreements ratified by the Parliament of Georgia, with whom the Ministry of Finance of Georgia has concluded a
project implementation authorisation agreement, to other persons under these projects;
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e) supply of goods outside of Georgia (export/re-export of goods). In addition, if the goods are to be carried outside of Georgia by a
passenger in his/her personal baggage, the tax privilege under this subparagraph shall only be applied when the passenger does not
live in Georgia (the place indicated in the passport or another personal identification document provided for by the legislation of
Georgia is not Georgia), transportation of goods from Georgia is carried out within 90 days from their supply and the price of
goods, including VAT, exceeds GEL 600.
Note: where goods are carried outside of Georgia by the passenger in his/her personal baggage, the procedure for applying the tax
privilege under this subparagraph shall be defined by the Minister of Finance of Georgia;
f) before placement of goods under the import, customs warehousing, temporary admission, inward processing or free zone
procedure, carriage of goods between the points located within the territory of Georgia and provision of services provided for by
paragraph 1(h) of this article and directly related to the above carriage, except for cargo storage services;
g) before admission to the territory of Georgia, carriage of goods placed under the import, customs warehousing, temporary
admission, inward processing or free zone procedure from the Georgian customs border to the point of destination specified in the
customs declaration and provision of services provided for by paragraph 1(h) of this article and directly related to the above
carriage, except for cargo storage services;
h) within the state border of Georgia, supply of fuel, lubricants and other ancillaries intended for the delivery on the board for
performing civil air flights and special services (aviation works);
i) provision of transportation, loading, unloading and storage services in relation to empty vehicles (including containers and
carriages) used during transportation;
j) when carrying out railway transportation in the territory of Georgia with a carriage/container owned by a non-resident,
provision of carriage/container usage service by the non-resident, except for the transfer of carriage/container on lease agreement;
k) when carrying out railway transportation outside of the territory of Georgia with a carriage/container owned by a Georgian
resident, provision by the Georgian resident of carriage/container usage services;
l) supply of goods by a person having the status of a special enterprise to the occupied territory of Georgia;
m) supply of Georgian goods to a duty free shop for sale and sale of goods and/or provision of food services at this location;
n) supply of gold to the National Bank of Georgia;
n1) supply of investment gold;
o) organised bringing of foreign tourists in the territory of Georgia by tour operators and supply of tourist products to them in the
territory of Georgia;
p) provision of services to a ship when bringing goods into the customs territory of Georgia (namely, provision of hydrographic
services by the port, the pilotage service and by the Legal Entity under Public Law within the system of the Ministry of Economics
and Sustainable Development of Georgia – the Maritime Transport Agency);
q) supply of foreign goods to a customs warehouse, except as provided for in Article 1641(4) of this Code;
r) provision of services involving lotteries, gambling and other games of chance by a lottery organiser under the Law of Georgia on
Organising Lotteries, Gambling and Games of Chance in which over 50% of interest is held by the State;
s) transfer of the property of a person (except for money) to the State, an autonomous republic or a local self-governing unit within
the scope of enforcement measures, including tax enforcement measures in favour of the State Budget, republican budget of an
autonomous republic or local self-governing unit’s budget, also the sale/transfer of a person’s property for the purpose of collecting
penalties imposed under criminal or administrative procedures;
t) supply of agricultural produce produced in Georgia (except for the goods (eggs) provided for under the NCNFEA Codes 0407 11
000 00 and 0407 21 000 00 and the goods specified under the subheading 0207 11 (gallus domesticus – uncut, fresh or refrigerated))
before their industrial processing (change of the commodity code);
u) supply of products obtained from goods fully produced in Georgia that are provided for under the NCNFEA Codes 0201, 0203
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11–0203 19, 0204 10 000 00–0204 23 000 00, 0204 50 110 00–0204 50 390 00 (including in a minced/chopped form (forcemeat)),
and supply of cheese made as a result of industrial processing of products obtained from animal habitants of Georgia, and supply of
goods (shelled nuts) provided for under the NCNFEA Code 0802 22 000 00;
v) supply by a Tourist Enterprise of hotel assets or part of the assets to another person for the purpose of receiving them back. If
within two years after supplying the hotel assets or part of the assets to another person the Tourist Enterprise receives the same
assets back under a commutative contract, the transaction shall also be VAT exempt with the right of deduction and this shall be a
basis for adjusting the amount of the taxable transaction. In that case, the Tourist Enterprise may adjust the amount of the taxable
transaction under the procedure established by Article 179 of this Code;
w) gratuitous provision of hotel services (hotel accommodation) for a maximum of 60 days during a calendar year to the owner of
the hotel assets or part of the assets by a Tourist Enterprise and/or by the person/persons invited under an appropriate contract to
ensure the functioning/operation of the facility or part of the facility as a hotel;
x) international call termination services in a mobile or fixed network in Georgia;
y) for the purpose of processing goods placed under the inward processing procedure, provision of services provided for in Article
6(1)(z1.a), (z1.b), (z1.d) and (z1.e) of the Customs Code of Georgia by a person carrying out the aforementioned procedure (except
if the processed goods were subsequently imported);
z) supply of electricity and guaranteed capacity, except for the supply of electricity to a consumer provided for by the Law of
Georgia on Energy and Water Supply who purchases electricity for own consumption, and provision of transmission and/or
dispatching services;
z1) provision of air carriage and transportation services and performance of special services (aviation works) within the state
border of Georgia;
z2) supply of ferrous and/or non-ferrous scrap metals and ferrous and/or non-ferrous metal waste if the party accepting the goods
can be identified. In addition, it shall be considered that the person accepting goods has been awarded a VAT deduction according
to the accounting period of supplying goods.
Note: the goods specified in this sub-paragraph are exclusive of ferrous castings, ingots, rolls, other raw materials and semi-
products of primary conversion that are classified under the NCNFEA commodity items 7201, 7202, 7203, 7205, 7206, 7207 and
commodity sub-item 7204 50 000 00;
z3) supply of goods (a book) provided for under the NCNFEA Codes 4901 and 4903 00 000 00, or of an electronic book, and
provision of sales and printing services for the goods;
z4) supply of an electric bus specified under the NCNFEA Code 8702 40 000 00 (including an electric minibus);
z5) services provided in relation to the imported goods if the cost of the services is included in the taxable amount defined in
accordance with Article 1641(2)(b) of this Code;
z6) supply of goods produced in Georgia and intended for a therapeutic/medical purpose, or supply by a pharmaceutical enterprise
of its own pharmaceutical products. For the purpose of this subparagraph, the list of goods intended for a therapeutic/medical
purpose and of pharmaceutical products shall be defined by a joint order of the Minister of Displaced Persons from the Occupied
Territories, Labour, Health and Social Affairs of Georgia and the Minister of Finance of Georgia;
z7) in accordance with the Law of Georgia on Reduction of Food Loss and Waste and on Food Donation, free supply (delivery) of
food by a participant of the food delivery chain to a charity organisation/a food bank.
5. Supply of goods and/or provision of services and/or importation of goods shall be VAT exempt with the right of deduction if the
aforementioned is carried out within the scope of the international agreements ratified by the Parliament of Georgia and that have
come into force, and supply of such goods and/or provision of such services and/or importation of such goods under the
agreements are VAT exempt.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 3272 of 15 June 2023 – website, 4.7.2023
Law of Georgia No 3549 of 4 October 2023 – website, 24.10.2023
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 685 of 12 June 2025 – website, 16.6.2025
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 173 – VAT exemption of the import of goods
The following shall be VAT exempt:
a) according to the list determined by a joint order of the Minister of Displaced Persons from the Occupied Territories, Labour,
Health and Social Affairs of Georgia and the Minister of Finance of Georgia:
a.a) the import of raw materials and/or substances provided for under the NCNFEA Groups 28 and 29 intended for
therapeutic/pharmaceutical purpose;
a.b) the import of goods intended for therapeutic/pharmaceutical purpose;
a.c) the import of goods necessary for the movement of a person with disability since childhood, and of a person with distinct and
significant disability;
a.d) the import of baby food products and/or child hygiene products;
a.e) the import of goods provided for under the NCNFEA Code 9619 00;
b) the import of goods provided for under the NCNFEA Group 30;
c) the import of radiopharmaceutical agents registered by the Ministry of Internally Displaced Persons from the Occupied
Territories, Labour, Health and Social Affairs of Georgia and provided for under the NCNFEA Code 2844; of goods provided for
under the NCNFEA Codes 8419 20 000 00, 9001 30 000 00, 9001 40 and 9001 50; under the Codes 9018–9022 (except for the Code
9022 29 000 00); under the Codes 9025 11 200 00 and 9402 90 000 00; of wheelchairs and their parts and accessories, medical X-ray
films, medical diagnostic testing systems, glucometers (testing systems of which are registered by the Ministry of Internally
Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia) provided for under the NCNFEA
Codes 8713 and 8714 20 000 00;
d) the import of goods provided for under the NCNFEA Codes 4801, 4802 55, 4802 61 150 00 and 4810 22;
e) the import of liquorice roots provided for under the NCNFEA commodity subheading 1211 90 960 00; of goods specified under
the commodity subheadings 1211 20 000 00; of natural untreated shellac provided for under the commodity subheadings 1301 20
000 00 and 1301 90 000 00; of goods provided for under the NCNFEA Codes 1504 20, 1515 30, 1520 00 000 00, 1702 11 000 00,
3912 12 000 00, 3912 31 000 00, 7010 10 000 00, 7010 90 790 00 and 9602 00 000 00 (gelatine capsules);
f) the import of goods provided for under the NCNFEA Codes 0102 21, 0103 10 000 00, 0104 10 100 00, 0104 20 100 00, 0105 11,
0511 10 000 00, 0602 10, 2503 00, 2803 00, 3101 00 000 00, 3103–3105 (except for a mechanical mixture), 3808 61 000 00, 3808 62
000 00, 3808 69 000 00, 3808 91, 3808 92 and 3808 93;
g) the import of a motor car under the NCNFEA Code 8703 and/or a motor cycle (including a moped) under the Code 8711;
h) the import of goods under the NCNFEA commodity subheading 8903;
i) the import of excise stamps by the Revenue Service and/or by a person selected by the Revenue Service under the procedure
established by the legislation of Georgia;
j) the import of treasures and/or of a movable thing transferred to state ownership;
k) the import of diabetic bread marked as such;
l) the import of goods provided for under the NCNFEA Codes 4901, 4902 და 4904 00 000 00 (magazines, newspapers and printed
http://www.matsne.gov.ge 20000000005001016012
music);
m) the import of a vehicle provided for under the NCNFEA Codes 8703 10 110 00;
n) the import of money (except for a collectible item and/or a coin with numismatic value), and of securities;
o) the import of chassis, bodies, parts and equipment specified under the NCNFEA Codes 8706 00 190 00, 8706 00 990 00, 8707 90
900 00, 8708 10 900 00, 8708 29 900 00, 8708 30 910 00, 8708 30 990 00, 8708 40 500 00-8708 40 990 00, 8708 50 990 00, 8708 70
500 00-8708 70 990 00, 8708 80 350 00-8708 80 990 00, 8708 91 350 00-8708 91 990 00, 8708 92 350 00-8708 92 990 00, 8708 93
900 00, 8708 94 350 00-8708 94 990 00, 8708 99 930 00 and 8708 99 970 00 intended for tractors specified under the NCNFEA
Codes 8701 91 100 01, 8701 91 100 05, 8701 92 100 01, 8701 92 100 05, 8701 93 100 01, 8701 93 100 05, 8701 94 100 01, 8701 94
100 05, 8701 95 100 01 and 8701 95 100 05, and of goods provided for under the NCNFEA Codes 8432 90 000 00 and 8433 90 000
00;
p) the import of natural gas for generation of electricity (for thermal power stations);
q) the import of agricultural pesticides and agrochemicals, seeding and planting materials of agricultural crops, according to the list
approved by an ordinance of the Government of Georgia;
r) the import of fuel contained in a standard tank structurally and technologically connected to the engine feed system of the
motor vehicle of a person entering Georgia in a motor vehicle;
s) the import of goods provided for under the respective NCNFEA Codes 8802 11 000 10, 8802 12 000 10, 8802 20 000 10, 8802 30
000 10 and/or of goods intended for them (for civil aviation) under the NCNFEA;
t) the import of gold to be transferred to the National Bank of Georgia;
t1) the import of investment gold;
u) the import of:
u.a) the returned goods provided for by Article 107 of the Customs Code of Georgia if the aforementioned goods meet the
conditions defined by the same article for exemption from import tax, irrespective of whether the goods are subject to import tax
or not;
u.b) the processed products derived from the processing of goods placed under the outward processing procedure in accordance
with Article 152 of the Customs Code of Georgia if the aforementioned goods meet the conditions defined by the same article for
exemption from import tax, irrespective of whether the goods are subject to import tax or not;
v) the import of goods to be transferred to the state and/or public organisations of Georgia for the elimination of a natural disaster,
accident and catastrophe, for the purpose of humanitarian aid;
w) the import of property of a diplomatic mission or consular office of Georgia abroad;
x) the import of goods in accordance with an international diplomatic and consular agreement if the goods were exempted from
import tax;
y) the import of goods exempted from customs obligations under Book X, except for the import of goods from a FIZ;
z) the import by a person selected by the Revenue Service under the procedure established by the legislation of Georgia of goods
intended for mandatory stamping/marking of excisable and/or non-excisable goods;
z1) the import of goods provided for under a grant agreement by a grantor or a grantee;
z2) the import of personal effects and household items intended for personal use by foreign citizens (including the family members
living with them) engaged in the oil and gas survey and extraction works;
z3) the import of goods intended for official use by a foreign diplomatic or equivalent mission, and for personal use by the
diplomatic and administrative and technical personnel (including the family members living with them) of the mission, in the
manner as it is provided for under appropriate international agreements to which Georgia is a party;
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z4) the import of the equipment and machinery, vehicles, spare parts and materials intended for performing oil and gas operations
provided for by the Law of Georgia on Oil and Gas, and for performing oil and gas operations for the investors and operating
companies under the agreements defined by the aforementioned Law and/or under the licences granted for performing oil and gas
operations;
z5) the import of goods by an international representation recognised by an appropriate authorised body under the conditions and
within the limit provided for by the international convention;
z6) the import, to a port, of the goods caught by a person carrying out fishing, which are not processed or were processed before
selling;
z7) the import and/or supply of goods intended for the delivery on the board for performing international civil flights and
international voyages, and the import of fuel, lubricants and other ancillaries intended for the delivery on the board for
performing civil air flights and special services (aviation works) within the state border of Georgia;
z71) the import of goods provided for under the NCNFEA Codes 4901 and 4903 00 000 00 (books);
z72) the import of an electric bus provided for under the NCNFEA Code 8702 40 000 00 (including an electric minibus);
z73) the import of goods funded with a soft loan issued by a foreign state and/or an international organisation under an
international agreement of Georgia ratified by the Parliament of Georgia, for the rehabilitation of the power sector.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1165 of 17 December 2021 – website, 28.12.2021
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3272 of 15 June 2023 – website, 4.7.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Chapter XXVI – VAT Deduction, Adjustment and Refund
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 174 – General provisions
1. The VAT deduction shall be the right of a taxable person to reduce the amount of VAT due by the amount of VAT directly
assigned to the value of various components of charges related to the supply of goods/provision of services.
2. The right of VAT deduction shall arise from the moment when the obligation to assess the deductible amount of VAT arises
(from the moment of VAT assessment of a transaction concerned).
3. Only a taxable person registered as a VAT taxpayer shall have the right to deduct VAT.
4. The procedure for obtaining the VAT deduction shall be defined by an order of the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 175 – The right of VAT deduction
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1. If goods/services are intended or used for carrying out a VAT taxable transaction, a taxable person shall have the right to deduct:
a) the VAT paid/payable for purchasing the goods/services from another taxable person in the territory of Georgia;
b) the VAT payable in relation to the transactions considered the supply of goods or provision of services under this Section;
c) the VAT paid/payable at import of goods;
d) the VAT assessed in the case of VAT reverse charge.
2. A taxable person shall, except as provided for by paragraph 1 of this article, have the right to deduct the amount of VAT related
to the charges borne with regard to the purchase of goods/services if the goods or services are used:
a) for provision of services/supply of goods outside of the territory of Georgia;
b) under Article 172 of this Code, in the transactions exempted from VAT with the right of deduction;
c) for financial services/transactions if the customer is established outside of Georgia, or if these transactions are directly related to
the goods that must be exported from Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 176 – The procedure for enjoying the VAT deduction
1. Grounds for obtaining VAT deduction shall be as follows:
a) where so provided for by Article 175(1)(a) and (b) and (2) of this Code, a tax invoice drawn up under the procedure established
by this Code in relation to the purchase of goods/services;
b) where so provided for by Article 175(1)(c) of this Code, an import declaration, in relation to the import of goods;
c) the amount of reverse charged VAT assessed by a person registered as a VAT taxpayer in the case of reverse charge and included
in the VAT declaration, which at the same is a ground for obtaining deduction;
d) where so provided for by Article 1611 of this Code, an appropriate document confirming purchase of goods by a buyer, in
which the amount of money paid for purchasing the goods (including the VAT amount) must be indicated;
e) when assessing VAT in relation to the import of goods on the basis of a decision of a tax authority, a document confirming
payment of the assessed VAT to the budget.
2. The Minister of Finance of Georgia may define certain cases when the VAT can be deducted on the ground different from the
one under paragraph 1 of this article.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 177 – Proportional deduction of VAT
1. If a taxable person uses goods or services for transactions in relation to which he/she has the right to obtain VAT deduction, and
for transactions in relation to which he/she has no such right, only a part of the VAT amount which belongs to the transactions in
relation to which he/she has the right to obtain VAT deduction shall be deducted.
2. A deductible part of the VAT shall be calculated according to a fraction and shall be recorded as a percentage where:
a) a numerator is the amount of annual turnover of transactions, excluding VAT, in relation to which the VAT is subject to
deduction in accordance to Article 175 of this Code;
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b) a denominator is the amount of annual turnover of transactions, excluding VAT, which are present in the numerator and of
transactions in relation to which the VAT is not subject to deduction.
3. When calculating a proportion subject to VAT deduction, no account shall be taken of the amount of turnover related to:
a) the supply of a fixed asset used by a taxable person for his/her own activities;
b) the transactions related to an immovable thing or financial transactions, unless the transactions are the main activities of a
taxable person.
4. The amount of VAT deductible according to the accounting period shall be defined:
a) according to the annual percentage recorded in the previous tax year under paragraph 2 of this article, which is revised
according to the annual percentage of the current tax year, in the last accounting period of the same year;
b) in each accounting period, according to the monthly percentage recorded under paragraph 2 of this article, which is revised in
the last accounting period of the current tax year, according to the annual percentage, if no appropriate annual percentage of the
previous tax year is recorded.
5. If a fixed asset is used or is intended to be used by a taxable person for the transactions in relation to which he/she has the right
to obtain VAT deduction, and for the transactions in relation to which he/she has no such right but these transactions cannot be
separated, the VAT deduction shall be carried out as follows:
a) if the sum of transactions carried out by a taxable person according to the previous tax year, in relation to which he/she has no
right to obtain VAT deduction, is less than 20% of the total turnover (the total sum for supplying goods/providing services,
excluding VAT), the person shall have the right to fully obtain the VAT deduction for the fixed asset in the very first accounting
period, and in addition, to define the amount of VAT to be cancelled at the end of each calendar year in proportion to the relative
share of the sum of those taxable transactions in the sum of the total turnover of the calendar year in relation to which he/she has
no right to obtain VAT deduction;
b) a taxable person shall, except as provided for by subparagraph a) of this paragraph, have the right to obtain VAT deduction for a
fixed asset only in proportion to the relative share of the sum of those taxable transactions in the total turnover during the year
included in the declaration for the last accounting period of each calendar year, in relation to which he/she has the right to obtain
the VAT deduction.
6. For the purposes of paragraph 5 of this article, the amount of VAT to be cancelled (in the case of paragraph 5(a) of this article)
or deducted (in the case of paragraph 5(b) of this article) annually shall be calculated as follows:
a) in relation to an immovable thing – during 10 calendar years from the commissioning year, in the amount of one tenth of VAT
amount;
b) in relation to other fixed assets – during 5 calendar years from the commissioning year, in the amount of one fifth of VAT
amount.
7. Paragraphs 1-6 of this article shall not apply if the sum of the transactions in the unseparated transactions (in the transactions in
relation to which a person has the right to obtain VAT deduction and in the transactions in relation to which he/she has no such
right and these transactions cannot be separated) during a calendar year, in relation to which he/she has no right to obtain VAT
deduction, is less than 5% of the sum of the total turnover. In this case, the taxable person shall have the right to fully obtain the
VAT deduction.
8. Where so provided for by Article 160(3)(b) and Article 1601(2)(b) of this Code, the provisions under paragraphs 5 and 6 of this
article shall apply to the extent as they would apply in the case of purchasing a building/structure or repair services from another
person, respectively.
9. The amount assessed with VAT under Article 163(2) of this Code shall be included in the amount of VAT turnover provided for
by this article.
10. When registering/cancelling the registration as a VAT taxpayer, or supplying fixed assets, the amount of VAT to be
deducted/cancelled in relation to the fixed assets shall be defined in proportion to the use of the fixed assets in the VAT taxable
transactions according to the tax years. The procedure for applying this paragraph shall be defined by the Minister of Finance of
Georgia.
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Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 178 – Restrictions on the right of VAT deduction
The VAT shall not be deducted:
a) in relation to the amount of VAT assigned to the value of expenses borne for social purposes or on entertainment events, or of
representation expenses, except when the supply of goods/provision of services carried out within such events is subject to VAT
assessment;
b) considering Articles 174-177 of this Code, in relation to the amounts of VAT assigned to the value of expenses borne on
goods/services used or intended to be used in a taxable transaction in relation to which the person has no right of VAT deduction;
c) on the basis of a tax invoice which fails to allow the identification of the seller of goods/services or is not issued under the
procedure established by the legislation of Georgia;
d) on the basis of a tax invoice since the end of the calendar year of carrying out of a taxable transaction included therein three
years have passed. If the VAT was deducted on the third year since carrying out of a taxable transaction, the period of limitation
defined by Article 4(1), (3) and (5) of this Code in relation to the parties participating in the taxable transaction (within this
transaction) shall be extended by one year. In addition, the VAT shall be deducted on the basis of a declaration corresponding to
the last accounting period of not later than the year when this right arose (including on the basis of an adjusted declaration);
e) on the basis of a fake document, and by a tax invoice representing a fictitious transaction or a non-commodity transaction.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 179 – Adjustment of VAT amount
1. A VAT taxable amount and, consequently, a deductible amount of VAT shall be adjusted if the circumstances/factors, on the
basis of which the VAT taxable amount was defined when a taxable transaction was carried out, change.
2. The amount of a taxable transaction shall be adjusted in the accounting period when a circumstance causing the adjustment
occurs.
3. A deductible amount of VAT shall not be cancelled nor shall it be adjusted when inventory items are written off under the
procedure established by this Code, or if there is a loss of goods.
4. The cases of adjustments of VAT taxable amounts, and the procedure for drawing up and filing a document shall be defined by
the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 180 – A tax invoice
1. Unless otherwise established by this Code, a tax invoice shall be issued when a taxable person registered as VAT taxpayer
supplies goods or provides services to another taxable person. Where so defined by the Minister of Finance of Georgia, a simplified
invoice can be issued.
2. A tax invoice shall be issued in a writing or electronic form.
3. When a taxable person registered as VAT taxpayer supplies goods or provides services to an end consumer, a tax invoice shall be
issued if so requested by the consumer.
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4. If a person keeps record of the provision of services or the supply of goods (the guaranteed capacity, electricity, gas, water,
thermal energy, cooling energy or other similar goods) by cyclic assessments, when a consumer pays according to the amount of
goods supplied/services provided not during a calendar month but during a certain period (cycle), which may include the
accounting period as well as pre-accounting period, a tax invoice may be issued according to such period (cycle).
5. Forms and requisites of a tax invoice (including a simplified tax invoice), the procedures for issuing, recording and using
(including restricting the use of) it, and certain cases when a tax invoice is not issued after goods are supplied/services are
provided, shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 181 – Refund of the amount of VAT
1. The right of refund of the amount of VAT shall arise for a taxable person if the amount of VAT to be deducted exceeds the
amount of VAT to be assessed in the accounting period.
2. A grant recipient, who has purchased goods and/or services within a grant agreement, shall be entitled to a deduction or a
refund of the VAT paid for the goods/services, on the basis of a tax invoice or, in the case of reverse charge, of a document
evidencing payment of the VAT to the budget filed with a tax authority.
3. Where so provided for in paragraph 2 of this article, the VAT shall be deducted or refunded if a grant recipient has filed an
appropriate document with a tax authority within 3 months since the end of a month he/she carried out a taxable transaction.
4. Where so provided for in paragraphs 1-3 of this article, the amount of VAT shall be refunded under the procedure established
by Article 63 of this Code.
5. When taking goods purchased in Georgia out of the territory of Georgia, a foreign national shall be entitled to a refund of the
amount of VAT paid on the goods.
6. Where so provided for in paragraph 5 of this article, the amount of VAT shall be refunded:
a) on the basis of a special receipt made out by an authorised seller of goods;
b) if goods are taken out of the territory of Georgia within 3 months after they were purchased and the value of the goods
according to one receipt exceeds GEL 200 (excluding VAT).
7. The procedure for refunding the amount of VAT, the requirements to be complied with by an authorised seller of goods, and
the list of goods to which paragraphs 5 and 6 do not apply shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 1811 – Refund of the amount of VAT to a taxable person of an EU Member State
1. A taxable person of an EU Member State shall be entitled to a refund of the amount of VAT paid when purchasing goods (except
for an immovable thing)/services in Georgia or importing goods if the aforementioned person meets all of the following
conditions:
a) the person has no fixed establishment in Georgia or the place of his/her activity and/or permanent residence is not in Georgia;
b) the goods/services purchased in, or goods imported to Georgia by the person are used for VAT taxable transactions;
c) if a similar transaction is carried out, a person registered as VAT taxpayer in Georgia, under this Code, would have the right to
deduct the VAT paid.
2. A taxable person of an EU Member State shall, in order to have the amount of VAT refunded, designate an authorised
representative on whom the obligations provided for a taxpayer under this Code shall be imposed, within the scope of the refund
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of VAT amount.
3. The procedure and conditions for refunding the amount of VAT provided for by paragraphs 1 and 2 of this article, and the
requirements to be complied with by an authorised representative, shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
SECTION VII
EXCISE TAX
Chapter XXVII – Excise Tax
Article 182 – Excise taxpayer
1. An excise tax payer shall be a person who:
a) produces excisable goods in Georgia;
b) imports excisable goods into Georgia;
c) exports excisable goods out of Georgia;
d) supplies natural gas (in a gaseous state) to motor vehicles;
d1) (Deleted – 12.6.2020, No 6343);
e) (Deleted – 22.6.2016, No 5445);
f) provides termination services for international calls received from a resident or a non-resident person in a mobile or fixed
network;
g) supplies the goods he/she/it has imported and that are specified under the National Commodity Nomenclature of Foreign
Economic Activity Codes 2401, 2403 11 000 00, 2403 19 and 2403 91 000 00.
2. A manufacturer of goods produced in Georgia with raw materials of a customer shall be considered an excise taxpayer.
3. In cases provided for in paragraph 1(a–d) and (g) of this article, a person shall be considered an excise taxpayer only for the
aforementioned transactions.
4. During a sale of excisable goods by auction, direct sale or in any other way, as part of a tax liability collection security measure
or for any other pecuniary liability (except penalties imposed under criminal and administrative proceedings), as well as during
transfer of a collateral (excisable goods) to the possession of a creditor under a contractual obligation performance security measure
(guarantee), the excise tax payer on the transaction shall be considered the person buying and/or receiving excisable goods, if such
a transaction is excisable under Article 1901 of this Code.
5. During privatisation of excisable goods transferred to state property, the excise taxpayer on such a transaction shall be
considered a person buying the excisable goods.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2874 of 11 December 2014 – website, 23.12.2014
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
Law of Georgia No 6343 of 12 June 2020 – website, 19.6.2020
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 1024 of 11 November 2025 – website, 14.11.2025
Article 183 – Excisable object
An excise taxable object shall be:
a) an excise taxable transaction;
b) import of excisable goods;
c) export of excisable goods.
Article 184 – Excisable transaction, the time of an excisable transaction
1. Excisable transactions and the moment of performing excisable transactions shall be:
a) the moment of supply by the producer of excisable goods produced in Georgia and/or removal of such goods from a company
warehouse for sale;
b) the moment of transfer by the producer of excisable goods produced in Georgia with a customer’s raw materials to the
customer;
c) the moment of starting to use in-house manufactured excisable goods for producing non-excisable goods;
d) the moment of supplying natural gas (in a gaseous state) to motor vehicles;
d1) (Deleted – 12.6.2020, No 6343);
e) the moment of delivering international call termination services in a mobile or fixed network in Georgia;
f) the moment of supplying the goods specified under the National Commodity Nomenclature of Foreign Economic Activity Codes
2401, 2403 11 000 00, 2403 19 and 2403 91 000 00.
2. (Deleted – 20.12.2011, No 5556).
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 2874 of 11 December 2014 – website, 23.12.2014
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 6343 of 12 June 2020 – website, 19.6.2020
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 185 – Determining the amount of an excisable transaction, import of excisable goods and export of excisable goods
1. The amount of an excisable transaction, import of excisable goods and export of excisable goods shall be determined:
a) (Deleted – 19.4.2011, No 4547);
b) for an alcoholic beverage – by the volume of an alcoholic beverage or the volume of pure alcohol in an alcoholic beverage, or by
percentage of alcohol content;
c) for tobacco products (except for the tobacco products provided for in subparagraph c1) of this paragraph) – by the quantity or
weight of a tobacco product and/or according to the retail price;
c1) for raw tobacco or tobacco waste – by the weight of raw tobacco or tobacco waste;
d) for a petroleum product – by the weight (volume) of a petroleum product;
e) for a motor car (except for a sports car) and a motor cycle (including a motor bicycle) – by their age and engine displacement;
f) for natural gas (in a gaseous state) – by the volume of gas;
f1) for a natural gas condensate and/or liquefied natural gas – by the weight;
g) in the case of delivering international call termination services in a mobile or fixed network in Georgia – according to the
duration of a call;
h) for the liquid of an electronic cigarette – by the volume of the liquid.
11. Where so provided for by Article 54(2), (3) or (4) of the Customs Code of Georgia, the amount of the import of excisable goods
shall be defined in accordance with the procedure established by the same paragraph for calculating the amount of import tax.
2. When delivering international mobile communication services (except for international call termination services in a mobile or
fixed network in Georgia), the amount of a taxable transaction shall not include the amount received from delivering such services
to a non-resident company.
Law of Georgia No 4547 of 19 April 2011 – website, 5.5.2011
Law of Georgia No 2874 of 11 December 2014 – website, 23.12.2014
Law of Georgia No 2949 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1378 of 15 November 2017 – website, 17.11.2017
Law of Georgia No 5075 of 2 October 2019 – website, 7.10.2019
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
Law of Georgia No 6343 of 12 June 2020 – website, 19.6.2020
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 2882 of 16 May 2023 – website, 25.5.2023
Law of Georgia No 1477 of 1 April 2026 – website, 1.4.2026
Article 186 – Import of excisable goods and the time of import
1. The import of excisable goods shall be the placement of the goods under the Release for free circulation procedure under the
Customs Code of Georgia.
2. The import of excisable goods shall be considered to have been performed if, under the Customs Code of Georgia, the goods are
placed under the Release for free circulation procedure.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 187 – Export of excisable goods and the time of export
1. The export of excisable goods shall be the placement of the goods under the export procedure under the Customs Code of
Georgia.
2. The export of excisable goods shall be considered to have been performed if, under the Customs Code of Georgia, the goods are
placed under the export procedure.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 188 – Excise tax rates for excise goods (except for alcoholic beverages)
1. The excisable goods indicated in this paragraph shall be subject to the following excise tax rates:
Unit of Excise tax rate
No CN code Description
measurement (GEL)
1 (Deleted – 23.12.2017, No 1935)
2 (Deleted – 23.12.2017, No 1935)
Tobacco products
2401 raw tobacco, tobacco waste 1 kg 30
2402 10 000 01 -- cigars, cheroots, containing tobacco 1 cigarette 2.1
2402 10 000 02 -- cigarillos (thin cigars), containing tobacco 20 cigarettes 2.4
3
- cigarettes, containing tobacco 20 cigarettes 2.75
2402 20
Cigarettes of local production, containing tobacco,
20 cigarettes 1.3
up to 35 million packs/packages annually
-- hookah tobacco, according to note 1 for a
2403 11 000 00 1 kg 30
subheading of this group
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2403 19 -- the rest 1 kg 30
2403 91 000 00 -- homogenised or recovered tobacco 1 kg 30
-- chewing or snuffing tobacco
2403 99 100 00 1 kg 30
2403 99 000 00 -- containing tobacco or recovered tobacco 20 pcs/cigarettes 2.70
2404 12 000 00 -- the rest, containing nicotine 1 ml 1.2
2404 19 900 00 --- the rest 1 ml 1.2
4 (Deleted – 1.4.2026, No 1477)
A motor cycle (including a motor bicycle) (according to the difference between the year of a taxable transaction
and the year of manufacture of a motor cycle (including a motor bicycle), and in the case of importation – the
difference between the year of registration of a customs declaration and the year of manufacture of a motor
cycle (including a motor bicycle), 1 cm3 of the engine displacement
a) under 1 year 1 cm3 1.5
b) 1 year old 1 cm3 1.3
c) 2 years old 1 cm3 0.7
d) 3 years old 1 cm3 0.7
e) 4 years old 1 cm3 0.7
f) 5 years old 1 cm3 0.7
g) 6 years old 1 cm3 0.8
h) 7 years old 1 cm3 0.8
i) 8 years old 1 cm3 0.8
j) 9 years old 1 cm3 0.8
8711
k) 10 years old 1 cm3 1.0
41 (except for a
wheelchair
under the
l) 11 years old 1 cm3 1.3
commodity item
8711) m) 12 years old 1 cm3 1.5
n) 13 years old 1 cm3 1.8
o) 14 years old 1 cm3 2.1
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p) over 14 years old 1 cm3 2.4
Petroleum gas product and natural gas (except for those carried through the pipeline)
2709 10 100 00 –gas condensate, natural 1 tonne 300
2711 11 000 00 --natural gas (liquefied) 1 tonne 300
2711 12 --Propane 1 tonne 300
2711 13 --Butanes 1 tonne 300
2711 14 000 00 --Ethylene, propylene, butylene and butadiene 1 tonne 300
5 2711 19 000 00 --the rest 1 tonne 300
2711 21 000 00 --natural gas (in a gaseous state) 1000 m3 200
2901 10 000 00 –saturated 1 tonne 300
2901 23 000 00 --butene (butylene) and its isomers 1 tonne 300
Petroleum products, petroleum distillates and used oil products
2710 12 --light distillates and products 1 tonne 500
2710 19 110 00 ----for specific refining processes 1 tonne 440
1 tonne
----for chemical transformations in the processes, except
2710 19 150 00 440
for those specified in subheading 2710 19 110 00
2710 19 210 00 -----jet fuel 1 tonne 440
2710 19 250 00 -----the rest 1 tonne 440
2710 19 290 00 -----the rest 1 tonne 440
1 tonne
2710 19 310 00 -----for specific refining processes 400
2710 19 350 00 1 tonne
-----for chemical transformations in the processes, except
400
for those specified in subheading 2710 19 310 00
2710 19 430 00 1 tonne
------containing sulphur of not more than 0.001 mass % 400
2710 19 460 00 1 tonne
------containing sulphur of over 0.001 mass % but not more
400
than 0.002 mass %
------ containing sulphur of over 0.002 mass % but not
2710 19 470 00 1 tonne 400
more than 0.1 mass %
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2710 19 480 00 ------ containing sulphur of over 0.1 mass % 1 tonne 400
2710 19 710 00 -----for specific refining processes 1 tonne 800
2710 19 750 00 1 tonne
-----for chemical transformations in the processes, except
800
for those specified in subheading 2710 19 710
1 tonne
2710 19 810 00 ------motor oils, compressor lube oils, turbine lube oils 800
2710 19 830 00 ------liquids for hydraulic purposes 1 tonne 800
2710 19 850 00 ------white oils, paraffin oil 1 tonne 800
1 tonne
2710 19 870 00 ------sprocket oils and reduction gear box oils 800
1 tonne
------metal-working compounds, mould-release oils, anti-
2710 19 910 00 800
corrosion oils
6
2710 19 930 00 ------electrical insulating oils 1 tonne 800
2710 19 990 00 ------other lubricating oils and other oils 1 tonne 800
1 tonne 400
2710 20 110 00 ------containing sulphur of not more than 0.001 mass %
1 tonne 400
------ containing sulphur of over 0.001 mass % but not
2710 20 160 00
more than 0.1 mass %
400
2710 20 190 00 ------ containing sulphur of over 0.1 mass % 1 tonne
2710 20 900 00 --the rest 1 tonne 800
--Containing polychlorinated biphenyls (PCBs), 1 tonne 800
2710 91 000 00 polychlorinated triphenyls (PCTs) or polybrominated
biphenyls (PBBs)
1 tonne 100
Used oil products – bilge water (water contaminated with
oil), tank (oil products storage tank) wash-down
2710 99 000 00 Other used oil products 1 tonne 800
Biodiesel
7 3826 00 Biodiesel and mixtures thereof, not containing or 1 tonne 150
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containing less than 70 mass % of mass of petroleum or
oil products obtained from bituminous minerals
Liquid product of pyrolysis
8 3911 90 Liquid product of pyrolysis 1 tonne 400
Oils and other products distilled from coal tars at high temperature
1 tonne 350
----crude light oils, of which 90 vol.% or more than 90
2707 99 110 00
vol.% are distilled at a temperature below 200 o C
2707 99 190 00 ----the rest 1 tonne 350
2707 99 300 00 ---sulphurated light oils; anthracene 1 tonne 350
9
2707 99 500 00 ---basic products 1 tonne 350
2707 99 990 00 ----the rest 1 tonne 350
Admixture, solvent, anti-detonator
2707 10 100 00 - benzole 1 tonne 400
2707 20 000 00 - toluene 1 tonne 400
2707 30 000 00 - xylene 1 tonne 400
2707 20 900 00 --for other purposes 1 tonne 400
- other mixture of aromatic hydrocarbons, of which 65
vol. % or more than 65 vol. % (including losses) are
2707 50 000 00 1 tonne 400
distilled at a temperature below 250°C, with ISO 3405
method (ASTM D-86 equivalent method)
2707 99 800 00 ---phenols 1 tonne 400
--Synthetic paraffin with molecular mass of 460 or over
2712 20 100 00 1 tonne 400
460 but not in excess of 1560
2712 20 900 00 --the rest 1 tonne 400
2902 11 001 00 ---to be used as fuel 1 tonne 400
2902 11 009 00 ---for other purposes 1 tonne 400
2902 19 001 00 ---cyclic terpenes 1 tonne 400
2902 19 009 00 ---the rest 1 tonne 400
2902 20 000 00 -benzole 1 tonne 400
2902 30 001 00 --to be used as fuel 1 tonne 400
2902 30 009 00 ---for other purposes 1 tonne 400
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2905 11 000 00 --Methanol (methyl alcohol) 1 tonne 400
400
--Propan-1-ol (propyl alcohol) and propan-2-ol
2905 12 000 00 1 tonne
(isopropyl alcohol)
2905 13 000 00 1 tonne 400
--Butan-1-ol (n butyl alcohol)
2905 14 100 00 --2-methylpropan-2-ol (tert-butyl alcohol) 1 tonne 400
10 2905 14 900 00 ---the rest 1 tonne 400
2905 16 200 00 ---octan-2-ol 1 tonne 400
2905 16 850 00 ---the rest 1 tonne 400
3811 11 100 00 ---based on tetraethyl-lead 1 tonne 400
3811 11 900 00 ---the rest 1 tonne 400
3811 19 000 00 --the rest 1 tonne 400
1 tonne 400
--containing petroleum or oil products obtained from
3811 21 000 00
bituminous minerals
3811 29 000 00 ---the rest 1 tonne 400
3811 90 000 00 --the rest 1 tonne 400
3814 00 100 00 -based on butyl acetate 1 tonne 400
3814 00 900 00 -the rest 1 tonne 400
Lubricants
--preparations for the treatment of textile materials,
3403 11 000 00 1 tonne 800
leather, furs or other materials
---containing 70 mass % or more than 70 mass % of 800
3403 19 100 00 petroleum or oil products obtained from bituminous 1 tonne
minerals
---- biobased (1) lubricants, containing carbon of not 1 tonne
3403 19 200 00 less than 25 mass % that are biodegradable at a level of 800
not less than 60%
3403 19 800 00 ----the rest 1 tonne 800
1 tonne
--Preparations for the treatment of textile materials,
3403 91 000 00 800
leather, furs or other materials
11
3403 99 000 00 ---the rest 1 tonne 800
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12 (Deleted – 15.12.2023, No 4022).
Symmetrical ethers, or acyclic aldehydes
---Tert-butyl ethyl ether (ethyl-tertio-butyl-ether,
2909 19 100 00 1 tonne 400
ETBE)
2909 19 900 00 ---Other 1 tonne 400
13
2912 11 000 00 ---Methanal (formaldehyde) 1 tonne 400
Note:
1. Goods specified in cell 3 of this Table and indicated under codes 2403 11 000 000, 2403 19 or 2403 91 000 00 of the Foreign
Economic Activity National Commodity Nomenclature may only be supplied if they are packed in primary packaging of 50 g or
100 g of net weight, except for the case when tobacco products are supplied for production purpose as defined by an order of the
Minister of Finance of Georgia. For the purposes of this Code, packing of the goods under this paragraph in primary packaging
shall not be the production of excisable goods.
2. (Deleted – 23.12.2017, No 1935).
3. (Deleted – 1.4.2026, No 1477).
4. (Deleted – 1.4.2026, No 1477).
5. (Deleted – 1.4.2026, No 1477).
11. For calculating the excise amount:
a) the excise rate for 20 pieces of filter cigarettes/non-filter cigarettes, containing tobacco, specified under the code 2402 20 of the
Foreign Economic Activity National Commodity Nomenclature shall be the sum of the excise rate defined in paragraph 1 of this
article and 30% of the retail selling price of the goods;
a) the excise rate for 20 pieces of cigarettes, containing tobacco, specified under the code 2402 20 of the Foreign Economic Activity
National Commodity Nomenclature shall be the sum of the excise rate defined in paragraph 1 of this article and 20% of the retail
selling price of the goods;
a1) the excise rate for 20 pieces of cigarettes of local production of up to 35 million packs/packages annually, containing tobacco,
specified under the code 2402 20 of the Foreign Economic Activity National Commodity Nomenclature shall be the sum of the
excise rate defined in paragraph 1 of this article and 15% of the retail selling price of the goods;
b) the excise rate for 20 pieces of the capsules and similar products (containing tobacco) specified under Foreign Economic Activity
National Commodity Nomenclature code 2404 11 000 00, and for 20 pieces of cigarettes to be used for obtaining aerosol without
burning process shall be the sum of the excise rate defined in paragraph 1 of this article and 20% of the retail selling price of the
goods;
c) the excise rate for 20 pieces of goods specified under the code 2402 10 000 02 of the Foreign Economic Activity National
Commodity Nomenclature shall be the sum of the excise rate defined in paragraph 1 of this article and 30% of the retail selling
price of the goods.
Note: for the purpose of this paragraph, the retail sale price of the goods shall be determined based on the retail sale prices
presented by the producer/importer of this product to a tax authority and other information available at the tax authority not later
than 1 December of each year and shall be effective during one year from 1 January of the following year.
2
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1 . For calculating excise amount for cigarettes specified under the Foreign Economic Activity National Commodity Nomenclature
code 2402 20, and for the goods specified under the Foreign Economic Activity National Commodity Nomenclature codes 2402 10
000 02 and 2404 11 000 00, the retail sale price and the procedure for its calculation shall be defined by the Minister of finance of
Georgia.
2. (Deleted – 19.4.2011, No 4547).
3. The following shall be electronic communication service rates:
a) (Deleted – 22.6.2016, No 5445);
b) for international call termination services in a mobile network in Georgia – 15 tetris per minute;
c) for international call termination services in a fixed network in Georgia – 8 tetris per minute.
4. (Deleted – 22.6.2016, No 5445).
5. (Deleted – 23.12.2017, No 1935).
6. (Deleted – 23.12.2017, No 1935).
7. (Deleted – 23.12.2017, No 1935).
8. (Deleted – 12.6.2020, No 6343).
9. The excise rate for a sports car provided for under the commodity code 8703 of the Foreign Economic Activity National
Commodity Nomenclature shall be GEL 100.
10. The excise rate for a classic car provided for under the commodity code 8703 of the Foreign Economic Activity National
Commodity Nomenclature shall be GEL 1.0 for 1 cm3 of the engine displacement.
11. The procedure and conditions for application of the excise rate provided for by this article for cigarettes of local production of
up to 35 million packs/packages annually specified under the code 2402 20 of the Foreign Economic Activity National Commodity
Nomenclature, and the quoting procedure shall be defined by an ordinance of the Government of Georgia.
12. The excise rate for a 0 through 6 years old car provided for under the commodity item 8703 of the Foreign Economic Activity
National Commodity Nomenclature shall be GEL 1.5 for 1 cm3 of the engine displacement, unless otherwise established by this
article.
13. The excise rate for a car that is more than 6 years old as provided for under the commodity item 8703 of the Foreign Economic
Activity National Commodity Nomenclature shall be GEL 4.5 for 1 cm3 of the engine displacement.
14. The excise rate specified in paragraph 12 of this article for a 0 through 6 years old car provided for under the commodity item
8703 of the Foreign Economic Activity National Commodity Nomenclature in the case of a left hand drive hybrid car shall be
reduced by 60 %.
15. The excise rate for a 0 through 6 years old car provided for by paragraph 12 of this article, which is right hand drive or has
converted steering, shall be three times as much as the excise rate specified in the same paragraph.
16. The excise rate for a car that is more than 6 years old provided for by paragraph 13 of this article, which is right hand drive or
has converted steering, shall be three times as much as the excise rate specified in the same paragraph.
17. The excise rate for an electric engine car provided for under the commodity item 8703 of the Foreign Economic Activity
National Commodity Nomenclature, which is right hand drive or has converted steering, shall be GEL 3 000.
18. For the purposes of this article, the age of a car (except for a sports car) shall be defined as a difference between the year of the
taxable transaction and the production year of the car, and in the case of import, the age of a car shall be defined as a difference
between the year of registration of the customs declaration and the production year of the car.
Law of Georgia No 4547 of 19 April 2011 – website, 5.5.2011
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 906 of 30 July 2013 – website, 20.8.2013
Law of Georgia No 2874 of 11 December 2014 – website, 23.12.2014
Law of Georgia No 2949 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 4615 of 11 December 2015 – website, 22.12.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 4941 of 13 April 2016 – website, 19.4.2016
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1378 of 15 November 2017 – website, 17.11.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 4616 of 29 May 2019 – website, 30.5.2019
Law of Georgia No 5075 of 2 October 2019 – website, 7.10.2019
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
Law of Georgia No 6343 of 12 June 2020 – website, 19.6.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 2882 of 16 May 2023 – website, 25.5.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 4203 of 29 May 2024 – website, 13.6.2024
Law of Georgia No 134 of 13 December 2024 – website, 29.12.2024
Law of Georgia No 1114 of 26 November 2025 – website, 28.11.2025
Law of Georgia No 1477 of 1 April 2026 – website, 1.4.2026
Article 1881 – Excise tax rates for alcoholic beverages
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1. The alcoholic beverages provided for in this paragraph shall be taxable at the following excise rates:
Description/Name of goods Unit of measurement Rate
1 Beer 1 litre/1% Vol 0.12
2 Any other fermented beverage in which alcohol content exceeds 5% 1 litre 5
Any other fermented beverage in which alcohol content is 5% or less
3 1 litre 0.6
than 5%
4 Intermediary alcoholic beverage 1 litre 5
Beverage with high concentration of ethanol (except for goods under
the Foreign Economic Activity National Commodity Nomenclature 1 litre of pure
5 22.5
codes 2208 20, 2208 60, 2208 90 330 00, 2208 90 380 00, 2208 90 480 00alcohol
and 2208 90 710 00)
Goods under the Foreign Economic Activity National Commodity 1 litre of pure
6 7.5
Nomenclature code 2207 alcohol
Goods under the Foreign Economic Activity National Commodity
1 litre of pure
7 Nomenclature codes 2208 20, 2208 60, 2208 90 330 00, 2208 90 380 15
alcohol
00, 2208 90 480 00 and 2208 90 710 00
Note: the following items in the table:
a) ‘Beer’ includes the goods specified under the Foreign Economic Activity National Commodity Nomenclature code 2203, and
goods under codes 2206 00 590 01 and 2206 00 890 01 (a mixture of one or more than one non-alcoholic beverage specified under
the Foreign Economic Activity National Commodity Nomenclature code 2206 and beer), in which alcohol content exceeds 0.5%;
b) ‘Any other fermented beverage’ includes the goods specified under the Foreign Economic Activity National Commodity
Nomenclature codes 2205 and 2206 (except for beer and wine):
b.a) in which alcohol content exceeds 1.2% and does not exceed 10%;
b.b) in which alcohol content exceeds 10% and does not exceed 15% provided that the alcohol contained in the product is
completely obtained through fermentation;
c) ‘Intermediary alcoholic beverage’ includes the goods specified under the Foreign Economic Activity National Commodity
Nomenclature codes 2205 and 2206 (except for beer, wine and other fermented beverages), in which alcohol content exceeds 1.2%
and does not exceed 22%;
d) ‘Beverage with high concentration of ethanol’ includes:
d.a) the goods specified under the Foreign Economic Activity National Commodity Nomenclature code 2208, in which alcohol
content exceeds 1.2%;
d.b) the goods specified under the Foreign Economic Activity National Commodity Nomenclature codes 2205 and 2206, in which
alcohol content exceeds 22%.
2. Wine includes the goods specified under the Foreign Economic Activity National Commodity Nomenclature codes 2204 and
2205 produced with the use of grapes, in which alcohol content exceeds 1.2% and does not exceed 18% provided that the alcohol
contained in the final product is completely obtained through fermentation and without any additives.
3. The amount of excise tax to be paid on the goods specified in column 1 of the table in paragraph 1 of this article shall be the
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product of a respective excise rate and the figure of the volume of goods by the percentage of alcohol content in the goods.
4. The amount of excise tax to be paid on the goods specified in columns 2–4 of the table in paragraph 1 of this article shall be the
product of a respective excise rate by the figure of the volume of the goods.
5. The amount of excise tax to be paid on the goods specified in columns 5–7 of the table in paragraph 1 of this article shall be the
product of a respective excise rate by the figure of the volume of pure alcohol in the goods.
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Article 189 – Excise tax deductions
1. Unless otherwise provided for by this article, a person carrying out a taxable transaction or export of excisable goods shall be
entitled to an excise tax deduction in the amount of excise tax paid or payable on excisable goods (raw materials) used for the
production of supplied excisable goods (including delivered, removed from a warehouse for sale, or exported excisable goods) or to
a refund of excise tax in accordance with the procedure established for refunding the excess amount paid, but not more than the
excise tax calculated on goods produced using such goods.
2. The procedure for deducting or refunding excise tax provided for by the first paragraph of this article shall apply with respect to
excisable goods (raw materials) imported by a manufacturer for the production of excisable goods.
3. Under the first and second paragraphs of this article, excise tax shall be deducted or refunded if the manufacturer presents an
invoice and/or a customs entry evidencing that he/she has paid excise tax as a manufacturer of excisable goods (raw materials)
and/or on import of excisable goods (raw materials).
31. Where so provided for by Article 1901 of this Code, the basis for obtaining an excise tax deduction shall be the excise tax
amount assessed on transactions provided for by the same article and indicated in the excise tax declaration.
4. If other excisable and non-excisable goods are concurrently manufactured from excisable goods (raw materials), a deduction
shall be made in proportion to the amount of the excisable goods produced, but not more than the excise tax calculated on such
excisable goods.
5. In the event of importing or purchasing immature excisable goods, a person shall be entitled to obtain a tax deduction in the
amount of the excise tax paid or payable on such excisable goods (raw materials) or to receive a refund of the respective excise tax
in accordance with the procedure for refunding an excess payment.
6. (Deleted – 22.6.2016, No 5445).
7. (Deleted – 22.6.2016, No 5445).
8. If, after a motor car specified under Code 8703 or a motor cycle (including a motor bicycle) specified under Code 8711 of the
Foreign Economic Activity National Commodity Nomenclature is placed under the Release for free circulation procedure, this
transport vehicle gets registered under the export procedure and leaves the territory of Georgia within 180 calendar days, an
importer shall be entitled, under the established procedure, to refund for an excise tax paid on the transport vehicle in the amount
of 100%.
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1378 of 15 November 2017 – website, 17.11.2017
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
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Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 190 – Excise tax payment procedure
1. The accounting period for excise tax shall be a calendar month.
2. Excise tax shall be subject to payment by the 15th day of the month following the accounting period of performing an excisable
transaction except as provided for by the third paragraph of this article.
3. Excise tax on the import of goods shall be paid in accordance with the procedure applicable to payment of import duty.
4. (Deleted – 20.12.2011, No 5557).
Law of Georgia No 4547 of 19 April 2011 – website, 05.5.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5557 of 20 December 2011 – website, 28.12.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 1901 – Charging excise tax in certain cases
1. The sale of excisable goods by auction, direct sale or in any other way, as part of a tax liability collection security measure or for
any other pecuniary liability (except penalties imposed under criminal and administrative proceedings), as well as during transfer
of collateral (excisable goods) to the possession of a creditor under a contractual obligation performance security measure
(guarantee), shall be subject to excise tax under this article.
11. Privatisation of excisable goods transferred to state property shall be taxed in accordance with this article.
2. In this article:
a) the first paragraph shall not apply to:
a.a) sold/transferred excisable goods, if the owner of such goods has not produced them;
a.b) goods with affixed excise stamps, if excise tax has been paid at the time of buying excise stamps;
a.c) excisable goods received in the possession of a natural person, if such person does not further supply these goods and/or use
such goods for the production of other goods;
b) paragraph (11) shall not apply to:
b.a) excised or excisable goods;
b.b) excised goods received in the possession of a natural person, if such person does not further supply these goods and/or use
such goods for the production of other goods.
3. Where so provided for by this article, an excise taxpayer shall file an excise return, according to paragraphs (1) and (1 1) of this
article, if he/she:
a) supplies excisable goods – by no later than the 15th day of the month following the month of supply;
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b) uses excisable goods for the production of non-excisable goods – by no later than the 15th day of the month following the
month of using excisable goods for the production of non-excisable goods;
c) uses excisable goods for the production of other excisable goods – by no later than the 15th day of the month following the
month of supply of such other excisable goods.
4. Where so provided in this article, the excise taxpayer shall pay the excise tax payable to the budget within the time determined
by the third paragraph of this article for filing an excise return.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4680 of 18 December 2015- website, 29.12.2015
Law of Georgia No 1024 of 11 November 2025 – website, 14.11.2025
Article 1902 – Charging excise tax to a person having the status of special enterprise
For a person having the status of special enterprise, an object of excise taxation, and the procedures for calculation, reporting and
payment of the excise tax shall be determined by an ordinance of the Government of Georgia.
Law of Georgia No 2476 of 6 June 2018 – website, 21.6.2018
Article 191 – Filing a Return
1. For each accounting period, no later than the 15th day of the month following the accounting period of the tax authority, an
excise return indicating performed taxable transactions shall be filed by:
a) a manufacturer of excisable goods;
b) an excise taxpayer provided for by Article 182(1)(d, f and g) of this Code;
c) an excise tax payer defined by Article 192(6) and (7) of this Code, if the obligation to pay excise tax provided by the same
paragraphs arises.
11. To enjoy the tax benefit under Article 194(5)(g) of this Code, an excise tax payer shall file an excise return for each accounting
period with the tax authority, by no later than the 15 th day of the month following the accounting period.
2. The Minister of Finance of Georgia shall determine the procedure for filing an excise return and the excise return form.
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
Law of Georgia No 6343 of 12 June 2020 – website, 19.6.2020
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Article 192 – Excise stamps
1. Except as provided for by paragraphs 11 and 12 of this article, before performing an excisable transaction and/or import of
goods, and in cases provided for by Article 1901 of this Code, before goods are transferred to persons purchasing and/or receiving
them, the following shall be subject to mandatory affixing of excise stamps:
a) excisable alcoholic beverages;
b) tobacco products (including raw tobacco, or tobacco waste);
c) liquids containing nicotine or not containing nicotine, intended to be used in electronic cigarettes.
11. In cases of privatising alcoholic beverages that are transferred to state ownership, the mandatory affixing of excise stamps to
excise goods shall be performed by persons purchasing and/or receiving the excise goods immediately after finishing transportation
of the goods from a relevant agency to the place of storage.
12. If the goods specified under the codes 2404 12 000 00 and 2404 19 900 00 of the Foreign Economic Activity National
Commodity Nomenclature are imported, the procedure for mandatory affixing of excise stamps to excisable goods by the importer
shall be defined by an order of the Minister of Finance of Georgia.
2. Except as determined by the Minister of Finance of Georgia, the following goods shall be exempt from mandatory affixing of
excise stamps:
a) domestically manufactured goods intended for export;
b) goods to be supplied to a duty-free shop;
c) goods under import procedure, intended for the official use of foreign diplomatic missions and representations equated with
them, and for personal use of the diplomatic and administrative-technical personnel (including their family members residing
with them) of such representations;
d) goods under import procedure, intended for the personal use of foreign citizens (including their family members residing with
them) employed for the fulfilment of obligations under the international treaties of Georgia (construction of Baku-Tbilisi-Ceyhan
and Baku-Tbilisi-Erzurum Pipelines);
e) goods subject to mandatory affixing of excise stamps, which are returned in accordance with the Customs Code of Georgia;
f) alcoholic beverages bottled in containers of 0.05 litres or less, or in containers of more than 10 litres (except for beer);
g) imported alcoholic beverage of up to 4 litres – if delivered by parcel post;
g1) alcoholic beverage imported by a passenger – within the limited amount provided for in Article 194(5)(b2);
h) the import of goods specified under the codes 2401, 2403 11 000 00, 2403 19 and 2403 91 000 00 of the Foreign Economic
Activity National Commodity Nomenclature;
i) imported (including those delivered by parcel post) 200 cigarettes or 50 cigars or 50 cigarillos, or 200 pieces of tobacco product
provided for under the Foreign Economic Activity National Commodity Nomenclature code 2404 11 000 00, or 10 units of
capsules and similar products, or 250 grams of any other tobacco product, or a collection of sorts of tobacco product specified in
this sub-paragraph if the sum of percentage values (a percentage value in relation to the respective limited amount) of portions of
each sort of tobacco product contained therein does not exceed 100.
3. It shall be prohibited to:
a) perform a taxable transaction with and/or import goods missing excise stamps if such goods are subject to the mandatory affixing
of excise stamps (except those provided for by the second paragraph of this article) and transfer the goods to the persons
purchasing and/or receiving goods in the cases provided for in Article 1901 of this Code;
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b) supply to a retail network any on tap alcoholic beverages (except beer) and/or those bottled in containers of 10 litres or more in
volume.
31. An excise stamp may be in material or immaterial form. In the cases determined by the Minister of Finance of Georgia, the
mandatory affixing of excise stamps shall be performed by a person selected by the Revenue Service under the procedure defined
by an ordinance of the Government of Georgia.
4. Manufacturers and importers of excisable goods in the territory of Georgia (declarants), as well as payers of excise tax under
Article 182(4) and (5) of this Code shall pay the nominal value of an excise stamp. The nominal value, the procedure for its
payment and for labelling of goods shall be determined by order of the Minister of Finance of Georgia.
5. Tax/customs authorities shall, in accordance with the established procedure, confiscate excisable goods imported or received for
sale without excise stamps, in violation of the rules, when such goods are subject to mandatory affixing of excise stamps. Upon
confiscation, such goods shall be considered state property and shall be privatised or destroyed under the procedure established by
the Minister of Economy and Sustainable Development of Georgia.
6. For the purposes of this Section, a lack of excise stamps in any form (loss, destruction and other cases except force-majeure) shall
be regarded as import and supply of goods corresponding to the respective type of excise stamp by importers and as supply of
goods corresponding to the respective type of excise stamp by local manufacturers and shall be subject to excise tax at the highest
excise tax rate fixed for 1 piece/litre of goods corresponding to the respective type of excise stamp, manufactured/imported by a
person.
7. If a person fails to import goods/carry out an excise taxable transaction within 6 months after obtaining excise stamps, the excise
stamps shall be subject to be returned. Failure to return excise stamps exactly on the following day of the expiration of the six-
month period shall be considered, for the purposes of this Section, as the domestic supply of excisable goods subject to mandatory
affixing of excise stamps and shall be subject to excise taxation accordingly, whereas in a subsequent period, when the goods with
affixed unreturned excise stamps are imported/an excise taxable transaction is carried out, the excise assessed for payment shall be
recalculated pro rata to the amount of import/excisable transaction actually carried out.
Note: the procedure for applying this paragraph in the case provided for by paragraph 12 of this article shall be defined by an
order of the Minister of Finance of Georgia.
8. Excise marks may not be transferred to any other person except in the case when an importer of excisable goods subject to
mandatory affixing of excise stamps transfers excise stamps to a foreign manufacturer of excisable goods to have the manufacturer
affix the excise stamps to such goods.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5557 of 20 December 2011 – website, 28.12.2011
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 4680 of 18 December 2015- website, 29.12.2015
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1165 of 17 December 2021 – website, 28.12.2021
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Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 1024 of 11 November 2025 – website, 14.11.2025
Article 1921 – Mandatory marking of non-excisable goods
1. The Minister of Finance of Georgia shall be authorised to compile a list of non-excisable goods subject to mandatory marking
and the terms of marking.
2. The service of mandatory marking in material and immaterial forms shall be provided by a person selected by the Revenue
Service under the procedure defined by an ordinance of the Government of Georgia.
3. The nominal value of marking shall be levied for mandatory marking. The nominal value and payment terms shall be
determined by an order of the Minister of Finance of Georgia.
Law of Georgia No 5557 of 20 December 2011 – website, 28.12.2011
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 193 – Tax invoice
When selling excisable goods, an excise taxpayer shall issue and hand over to the recipient of goods, if so requested, a tax invoice
provided for by Article 180 of this Code.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 194 – Rules governing excise tax exemption
1. Excise exemption may be with or without the right to deduct.
2. Exempting a transaction with the right to deduct means that the transaction is not subject to excise tax assessment (is not
excised) and the right of deduction applies.
3. Exempting a transaction without the right to deduct means that the transaction is not subject to excise tax assessment (is not
excised) and the right of deduction does not apply.
4. The procedure of applying excise exemption shall be determined by an order of the Minister of Finance of Georgia.
5. The following shall be excise tax exempt without the right to deduct:
a) alcoholic beverages produced by a natural person for personal use;
b) import by a passenger of 200 cigarettes or 50 cigars or 50 cigarillos, or 200 pieces of tobacco product provided for under the
Foreign Economic Activity National Commodity Nomenclature code 2404 11 000 00, or 10 units of capsules and similar products,
or 250 grams of another tobacco product, or a collection of sorts of tobacco product specified in this sub-paragraph if the sum of
percentage values (a percentage value in relation to the respective limited amount) of portions of each sort of tobacco product
contained therein does not exceed 100, or total of 50 ml of goods provided for under the Foreign Economic Activity National
Commodity Nomenclature codes 2404 12 000 00 and 2404 19 900 00, which are carried in a baggage and/or hand luggage during
passenger transportation and which are not intended for economic activities;
b1) when imported by parcel post, 200 cigarettes or 50 cigars or 50 cigarillos, or 200 pieces of tobacco product provided for under
the Foreign Economic Activity National Commodity Nomenclature code 2404 11 000 00, or 10 units of capsules and similar
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products, or 250 grams of another tobacco product, or a collection of sorts of tobacco product specified in this sub-paragraph if the
sum of percentage values (a percentage value in relation to the respective limited amount) of portions of each sort of tobacco
product contained therein does not exceed 100, or total of 50 ml of goods provided for under the Foreign Economic Activity
National Commodity Nomenclature codes 2404 12 000 00 and 2404 19 900 00, and 4 litres of an alcoholic beverage;
b2) import by a passenger in total of 1 litre of alcoholic beverage with 22% and more than 22% alcohol content or of non-
denatured ethanol with 80% and more than 80% alcohol content, or 2 litres of alcoholic beverage with less than 22% alcohol
content, or import of collection of sorts of alcoholic beverages specified in this subparagraph (except for beer and wine) if the sum
of percentage values (percentage value in relation to the respective limited amount) of portions of each sort of alcoholic beverage
(except for beer and wine) contained in the collection does not exceed 100; also, import of 16 litres of beer, which is carried in a
baggage and/or hand luggage during a passenger transportation and which is not intended for economic activities;
c) fuel in the standard tank of the transport vehicle of a person entering Georgia by a transport vehicle, which is structurally and
technologically related to the engine feed system;
d) import of goods in accordance with the requirements established by Article 173(z2) and (z3) of this Code;
e) import and/or supply of goods intended for supply on board during international flights and international sea passages, and
importation and/or supply of fuel, lubricants and other auxiliary means intended to be supplied on board for the performance of
civil flights and special services (aviation works) within the state border of Georgia;
f) import and/or supply of petroleum products for performing oil and gas transactions provided for by the Law of Georgia on Oil
and Gas;
g) import of the goods provided for in box 10 of the table in Article 188(1) of this Code, and of the goods provided for in box 13 of
the same table and specified under the Foreign Economic Activity National Commodity Nomenclature code 2912 11 000 00 if the
goods are used for production of non-excisable goods.
Note: Excise tax shall be levied on the above-mentioned goods at the moment of import, and if an excise return has been filed, the
taxpayer shall be entitled to a refund and/or a deduction on future tax liabilities in the amount of excise tax paid;
h) the import of a motor car under Article 199(d.d) and (d.e) of this Code;
i) the import of:
i.a) the returned goods provided for by Article 107 of the Customs Code of Georgia if the aforementioned goods meet the
conditions defined by the same article for exemption from import tax, irrespective of whether the goods are subject to import tax
or not;
u.b) the excisable goods derived from the processing of excisable goods placed under the outward processing procedure in
accordance with Article 152 of the Customs Code of Georgia if the aforementioned goods meet the conditions defined by the same
article for exemption from import tax, irrespective of whether the goods are subject to import tax or not;
j) the import of the property of diplomatic missions and consular establishments of Georgia abroad;
k) left hand drive transportation vehicles specified under commodity item 8703 of the National Commodity Classification of
Foreign Economic Activities and electric engine transportation vehicles specified under commodity item 8711 of the National
Commodity Classification of Foreign Economic Activities;
k1) a transportation vehicle specified under the commodity item 8703 of the National Commodity Classification of Foreign
Economic Activities, which is designed for use by a disabled person if the import of the transportation vehicle is performed by a
disabled person who needs a wheelchair to move. The procedure for enjoying the privilege under this subparagraph shall be
defined by the order of the Minister of Finance of Georgia;
Note: an appropriate person may enjoy the privilege under this subparagraph once in three years.
l) alcoholic beverage (liquid) used for preparation of a pharmaceutical product;
m) alcoholic beverage, used for production of a drink, in which alcohol content does not exceed 1.2%;
n) the import of the goods transferred to state ownership.
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Note:
1. If the amount of an alcoholic beverage and/or tobacco product, or of the goods specified under the Foreign Economic Activity
National Commodity Nomenclature codes 2404 12 000 00 and 2404 19 900 00 exceeds the limited quantity provided for in
subparagraph b), b1) or b2) of this paragraph, the excise tax exemption under this article shall be applied within the above quantity
limits of the goods.
2. A natural person shall gain the right to enjoy the tax privileges under subparagraphs b–b2) of this paragraph from the age of
18.
3. During the importation/manufacturing of the goods under subparagraphs l) and m) of this paragraph an excise tax shall be
levied, and if an excise tax return is submitted, a person purchasing the goods from the importer/manufacturer may obtain a
refund of the excise amount paid and/or set it off for future tax liabilities.
4. For the purposes of subparagraphs b) and b2) of this paragraph, it shall be deemed that the goods are not intended for economic
activities if their import is one-off and they are intended to be used by the passenger personally or by his/her family members,
and/or as a gift. In addition, the import of goods shall be one-off if the import of the goods is carried out not more than once
during one calendar day when they are brought in by an air transport, and in other cases – during 30 calendar days.
6. The following shall be excise tax exempt with the right to deduct:
a) import of excisable goods only for the accounting period, for which the taxpayer presents the following documents to the tax
authority:
a.a) a tax invoice and a document evidencing payment of the amount indicated in the tax invoice to the supplier (if other excisable
goods (raw materials) manufactured by another person have been used for manufacturing of exported excisable goods;
a.b) a customs entry on the export of goods;
b) supply of Georgian goods to a duty-free shop for sale;
c) transfer of a person’s property (excisable goods) to the state, the autonomous republic or the municipality, as part of a measure
to secure collection (including tax liability collection) to the state budget, to the budget of an autonomous republic or the budget
of a municipality, as well as sale/transfer of a person’s property (excisable goods) for collection of penalties imposed under criminal
and administrative proceedings;
d) supply, by a producer of alcohol produced by distilling grape wine listed under sub-item 2208 20 of the National Commodity
Classification of Foreign Economic Activities, to a producer of goods under the same sub-item, for production of goods;
e) production of alcohol obtained by distilling grape wine provided for under the Foreign Economic Activity National Commodity
Nomenclature commodity sub-item 2208 20 by a producer with the raw materials of a customer and its passing to the customer if
the customer uses these goods for production of the goods provided for under the same commodity sub-item.
Note: where a tax privilege under sub-paragraph d) or e) of this article applies, if a purchaser/customer of the alcohol obtained by
distilling grape wine provided for under the Foreign Economic Activity National Commodity Nomenclature commodity sub-item
2208 20 does not use these goods for production of the goods provided for under the same commodity sub-item, the
purchaser/customer of the goods shall be considered as an excise payer in relation to the goods purchased/passed. In such a case,
the moment when the purchaser/customer starts using the goods in another activity shall be considered the time of conducting a
taxable transaction.
7. Import of goods and/or supply of goods and/or delivery of services shall be excise tax exempt with the right to deduct, if it is
performed under international agreements ratified by the Parliament of Georgia, that entered into force, where import of goods
and/or supply of goods and/or delivery of services is excise tax exempt in accordance with such international agreements.
Law of Georgia No 4470 of 22 March 2011 – website, 01.4.2011
Law of Georgia No 4547 of 19 April 2011 – website, 5.5.2011
Law of Georgia No 4720 of 31 May 2011 – website, 10.6.2011
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6439 of 12 June 2012 – website, 22.6.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1378 of 15 November 2017 – website, 17.11.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 4616 of 29 May 2019 – website, 30.5.2019
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 1165 of 17 December 2021 – website, 28.12.2021
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3272 of 15 June 2023 – website, 4.7.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 1649 of 9 June 2026 – website, 10.6.2026
SECTION VIII
IMPORT DUTY
Chapter XXVIII – Import Duty
Article 195 – Payer of import duty
The payer of import duty shall be a person moving goods across the customs border of Georgia, except for export.
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Article 196 – Dutiable object
An object of import duty shall be the customs value of goods crossing the customs border of Georgia from outside Georgia, unless
otherwise provided for by this Code.
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Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Article 197 – Import duty rates
1. A 12% rate of import duty shall apply to the customs value of the following goods:
No CN code Description
Live poultry, that is a domestic fowl (Gallus Domesticus), ducks, geese, turkeys and
1 0105
guinea fowls
2 0201 Meat of bovine animals, fresh or chilled
3 0202 Meat of bovine animals, frozen
4 0204 Meat of sheep or goats, fresh, chilled or frozen
5 0205 00 Meat of horses, asses, mules or hinnies, fresh, chilled or frozen
Edible offal of bovine animals, swine, sheep, goats, horses, asses, mules or hinnies,
6 0206
fresh, chilled or frozen
Meat and edible offal, of the poultry of
7 0207
Heading 0105, fresh, chilled or frozen
8 0208 Other meat and edible meat offal, fresh, chilled or frozen
Meat and edible meat offal, salted, in brine, dried or smoked; edible flours and meals
9 0210
of meat or meat offal
10 0401 10 100 00 --- In immediate packings of a net content not exceeding 2 l
11 0401 20 110 00 --- In immediate packings of a net content not exceeding 2 l
12 0401 20 910 00 --- In immediate packings of a net content not exceeding 2 l
13 0401 40 100 00 --- In immediate packings of a net content not exceeding 2 l
14 0401 50 110 00 --- In immediate packings of a net content not exceeding 2 l
15 0401 50 310 00 --- In immediate packings of a net content not exceeding 2 l
16 0401 50 910 00 --- In immediate packings of a net content not exceeding 2 l
17 0402 10 110 00 --- In immediate packings of a net content not exceeding 2.5 kg
18 0402 10 910 00 --- In immediate packings of a net content not exceeding 2.5 kg
19 0402 21 110 00 ---- In immediate packings of a net content not exceeding 2.5 kg
20 0402 21 910 00 ---- In immediate packings of a net content not exceeding 2.5 kg
21 0402 29 150 00 -----In immediate packings of a net content not exceeding 2.5 kg
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22 0402 29 910 00 ---- In immediate packings of a net content not exceeding 2.5 kg
23 0402 91 100 01 ---- In immediate packings of a net content not exceeding 2.5 kg
24 0402 91 300 01 ---- In immediate packings of a net content not exceeding 2.5 kg
25 0402 91 510 00 ---- In immediate packings of a net content not exceeding 2.5 kg
26 0402 91 910 00 ---- In immediate packings of a net content not exceeding 2.5 kg
27 0402 99 100 01 ---- In immediate packings of a net content not exceeding 2.5 kg
28 0402 99 310 00 ---- In immediate packings of a net content not exceeding 2.5 kg
29 0402 99 910 00 ---- In immediate packings of a net content not exceeding 2.5 kg
Yogurt, buttermilk, curdled milk and cream, kephir and other fermented or
30 0403 acidified milk and cream, whether or not concentrated or containing added sugar or
other sweetening matter or flavoured or containing added fruit, nuts or cocoa
31 0407 Birds' eggs, in shell, fresh, preserved or cooked
Birds' eggs, not in shell, and egg yolks, fresh, dried, cooked by steaming or by
32 0408 boiling in water, moulded, frozen or otherwise preserved, whether or not
containing added sugar or other sweetening matter
33 0409 00 000 00 Natural honey
34 0410 Insects and food products of animal origin, not specified or included elsewhere
35 0701 Potatoes, fresh or chilled
36 0702 00 000 00 Tomatoes, fresh or chilled
37 0703 Onions, shallots, garlic, leeks and other alliaceous vegetables, fresh or chilled
38 0704 Cabbages, cauliflowers, kohlrabi, kale, and similar edible brassicas, fresh or chilled
Carrots, turnips, salad beetroot, salsify, celeriac, radishes and similar edible roots,
39 0706
fresh or chilled
40 0707 00 Cucumbers and gherkins, fresh or chilled
41 0708 Leguminous vegetables, shelled or unshelled, fresh or chilled
42 0709 Other vegetables, fresh or chilled
Vegetables (uncooked or cooked by steaming or
43 0710
boiling in water), frozen
Vegetables provisionally preserved but unsuitable in that state for immediate
44 0711
consumption
45 0712 20 000 00 -- Onions
46 0712 31 000 00 -- Mushrooms of the genus Agaricus
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47 0712 32 000 00 -- Wood ears (Auricularia spp).
48 0712 33 000 00 -- Jelly fungi (Tremella spp.)
49 0712 34 000 00 Shiitake (Lentinus edodes)
50 0712 11 000 00 -- Other
Dried leguminous vegetables, shelled, whether or
51 0713
not skinned or split
Manioc, arrowroot, salep, Jerusalem artichokes, sweet potatoes and similar roots and
52 0714 tubers with high starch or inulin content, fresh, chilled, frozen or dried, whether or
not sliced or in the form of pellets; sago pith
53 0802 Other nuts, fresh or dried, whether or not shelled or peeled
54 0803 Bananas, including plantains, fresh or dried
55 0805 Citrus fruit, fresh or dried
56 0806 Grapes, fresh or dried
57 0807 Melons (including watermelons) and papaws (papayas), fresh
58 0808 Apples, pears and quinces, fresh
59 0809 Apricots, cherries, peach (including nectarines), plum and sloe, fresh
60 0810 Other fruit, fresh
Fruit and nuts, uncooked or cooked by steaming or boiling in water, frozen,
61 0811
whether or not containing added sugar or other sweetening matter
Fruit and nuts, provisionally preserved but unsuitable in that state for immediate
62 0812
consumption
Fruit, dried, other than that of headings 0801 to 0806; mixtures of nuts or dried
63 0813
fruits of this chapter
64 0902 Tea, whether or not flavoured
65 1101 00 Wheat or meslin flour
66 1102 Other cereal flours, except for wheat or meslin
67 1103 Cereal groats, meal and pellets
68 1105 Flour, meal, powder, flakes, granules and pellets of potatoes
Flour, meal and powder of the dried leguminous vegetables of heading 0713, of sago
69 1106
or of roots or tubers of heading 0714 or of the products of Chapter 8
70 1108 Starches; inulin
71 1109 00 000 00 Wheat gluten, whether or not dried
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72 1512 19 900 00 --- Other
Sausages and similar products, of meat, meat offal, blood or insects; food
73 1601 00
preparations based on these products
74 1602 10 00 -- Homogenised preparations
75 1602 20 -- Of liver of any animal
76 1602 31 -- Of turkeys
77 1602 32 -- Of domestic fowl (Gallus domesticus)
78 1602 39 --Other
79 1602 41 -- Hams and cuts thereof
80 1602 42 -- parts of shoulders and cuts thereof
81 1602 49 -- Other, including mixtures
82 1602 50 -of bovine animals
83 1701 12 --Beet sugar
84 1701 91 000 00 --Containing added flavouring or colouring matter
85 1701 99 --Other
Other sugars, including chemically pure lactose, maltose, glucose and fructose, in
86 1702 solid form; sugar syrups not containing added flavouring or colouring matter;
artificial honey, whether or not mixed with natural honey; caramel
87 1703 Molasses resulting from the extraction or refining of sugar
88 1704 Sugar confectionary (including white chocolate) not containing not include cocoa
89 19 Food preparations made of grain crops, grain, flour, starch or milk; pastry
Vegetables, fruit, nuts and other edible parts of plants, prepared or preserved by
90 2001
vinegar or acetic acid
91 2002 Tomatoes prepared or preserved otherwise than by vinegar or acetic acid
Mushrooms and truffles, prepared or preserved otherwise than by vinegar or acetic
92 2003
acid
Other vegetables prepared or preserved otherwise than by vinegar or acetic acid,
93 2004
frozen, other than products of heading 2006
Other vegetables prepared or preserved otherwise than by vinegar or acetic acid, not
94 2005
frozen, other than products of heading 2006
Vegetables, fruit, nuts, fruit-peel and other parts of plants, preserved by sugar
95 2006 00
(drained, glacé or crystallised)
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Jams, fruit jellies, marmalades, fruit or nut purée and fruit or nut pastes, obtained by
96 2007
cooking, whether or not containing added sugar or other sweetening matter
97 2008 19 --Other, including mixtures
98 2008 20 -Pineapples
99 2008 30 -Citrus fruit
100 2008 40 -- Pears
101 2008 50 --Apricots
102 2008 60 --Cherries
103 2008 70 --Peaches, including nectarines
104 2008 80 --Strawberries
105 2008 91 000 00 --Palm hearts
-- Blueberry, cranberry (Vaccinium macrocarpon, Vaccinium oxycoccos);
106 2008 93
lingonberry (Vaccinium vitis-idaea)
107 2008 97 -- Mixtures
108 2008 99 -- Other
Fruit or walnut juices (including grape must) and vegetable juices, unfermented and
109 2009 not containing added spirit, whether or not containing added sugar or other
sweetening matter
Extracts, essences and concentrates, of coffee, tea or maté and preparations with a
110 2101 basis of these products or with a basis of coffee, tea or maté; roasted chicory and
other roasted coffee substitutes, and extracts, essences and concentrates thereof
Sauces and preparations therefor; mixed condiments and mixed seasonings; mustard
111 2103
flour and meal and prepared mustard
112 2106 90 - Other
113 2201 10 190 09 ---- Other
114 2201 10 900 00 -- Other
115 2201 90 000 09 --- Other
116 2201 90 000 99 -- Other
Waters, including mineral waters and aerated waters, containing added sugar or
117 2202 other sweetening matter or flavoured, and other non-alcoholic beverages, not
including fruit, walnut or vegetable juices of heading 2009
118 2203 00 Beer made from malt
119 2302 10 - made from maize (corn)
120 2302 30 - made from wheat
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121 2302 40 - made from other cereals
Tobacco and industrial tobacco substitutes; products with nicotine content or
without nicotine content, intended for smoking, without burning process; other
122 24
nicotine-containing products intended for taking nicotine by humans (except for
nicotine-containing products intended for tobacco smoking cessation)
123 25 Salt; sulphur; soils and stone; plastering materials, limestone and cement
Organic surface-active agents (other than soap); surface-active preparations,
124 3402 washing preparations (including auxiliary washing preparations) and cleaning
preparations, whether or not containing soap (other than those of heading 3401)
Floor coverings of plastics, whether or not self-adhesive, in rolls or in the form of
125 3918
tiles; wall or ceiling coverings of plastics, as defined in note 9 to this chapter
Baths, shower-baths, sinks, washbasins, bidets, lavatory pans, seats and covers,
126 3922
flushing cisterns and similar sanitary ware, of plastics
Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and
127 3923
other closures, of plastics
Tableware, kitchenware, other household articles and hygienic or toilet articles, of
128 3924
plastic
129 3925 20 000 00 - Doors, windows and their frames and thresholds for doors.
130 3925 30 000 00 - shutters, blinds (including jalousie) and similar articles and parts thereof
131 3925 90 - Other
132 3926 90 - Other
Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded
133 4407
or end-jointed, of a thickness exceeding 6 mm
Sheets for veneering (including those obtained by slicing laminated wood), for
plywood or for similar laminated wood and other wood, sawn lengthwise, sliced or
134 4408
peeled, whether or not planed, sanded, spliced or end-jointed, of a thickness not
exceeding 6 mm
Wood (including strips and friezes for parquet flooring, not assembled) continuously
shaped (tongued, grooved, rebated, chamfered, V-jointed, beaded, moulded,
135 4409
rounded or the like) along any of its edges, ends or faces, whether or not planed,
sanded or end-jointed
136 4413 00 000 00 Densified wood, in blocks, plates, strips or profile shapes
Builders' joinery and carpentry of wood, including cellular wood panels, assembled
137 4418
flooring panels, shingles and shakes
Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, and
138 4420 similar articles, of wood; statuettes and other ornaments, of wood; wooden articles
of furniture not specified in group 94
139 4421 Other articles of wood
140 6801 00 000 00 Setts, curb-stones and flagstones, of natural stone (except slate)
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Worked monumental or building stone (except slate) and articles thereof, other than
goods of heading 6801; mosaic cubes and the like, of natural stone (including slate),
141 6802
whether or not on a backing; artificially coloured granules, chippings and powder,
of natural stone (including slate)
Millstones, grindstones, grinding wheels and the like, without frameworks, for
grinding, sharpening, polishing, trueing or cutting, hand sharpening or polishing
142 6804
stones, and parts thereof, of natural stone, of agglomerated natural or artificial
abrasives, or of ceramics, with or without parts of other materials
Natural or artificial abrasive powder or grain, on a base of textile material, of paper,
143 6805 of paperboard or of other materials, whether or not cut to shape or sewn or
otherwise made up
Slag-wool, rock-wool and similar mineral wools; exfoliated vermiculite, expanded
clays, foamed slag and similar expanded mineral materials; mixtures and articles of
144 6806
heat-insulating, sound-insulating or sound-absorbing mineral materials, other than
those of heading 6811 or 6812 or of Chapter 69
Articles of asphalt or of similar material (for example, petroleum bitumen or coal tar
145 6807
pitch)
Panels, boards, tiles, blocks and similar articles of vegetable fibre, of straw or of
146 6808 00 000 00 shavings, chips, particles, sawdust or other waste of wood, agglomerated with
cement, plaster or other mineral binders
147 6809 Articles of plaster or of compositions based on
148 6810 Articles of cement, of concrete or of artificial stone, whether or not reinforced
149 6811 Articles of asbestos-cement, of cellulose fibre-cement or the like
150 6812 91 000 00 - Clothing, clothing accessories, footwear and headgear
151 6812 99 900 00 --- other
Articles of stone or of other mineral substances (including carbon fibres, articles of
152 6815
carbon fibres and articles of peat), not elsewhere specified or included
- Containing, by weight, singly or together, more than 50 % of the elements Mg, Ca
153 6902 10 000 00 or Cr, expressed as MgO, CaO or Cr2O 3
154 6902 20 100 00 -- Containing, by weight, 93 % or more of silica (SiO2)
155 6902 20 910 00 --- Containing, by weight, more than 7 % but less than 45 % of alumina (Al2O 3)
156 6902 20 990 00 --- Other
157 6902 90 000 00 - Other
Articles of jewellery and parts thereof, of precious metal or of metal clad with
158 7113
precious metals
159 7115 90 001 00 -- of precious metal
Articles of natural or cultured pearls, precious or semi-precious stones (natural,
160 7116
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synthetic or reconstructed)
161 7117 Imitation jewellery
162 7308 10 000 00 - Bridges and bridge-sections
163 7308 40 000 00 - Equipment for scaffolding, shuttering, propping or pit-propping
164 7308 90 - Other
165 7309 00 100 00 - For gases (other than compressed or liquefied gas)
166 7309 00 300 00 -- Lined or heat-insulated
167 7309 00 590 00 --- Not exceeding 100 000 l
168 7309 00 900 00 - For solids
Tanks, casks, drums, cans, boxes and similar containers, for any material (other than
compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 l,
169 7310
whether or not lined or heat-insulated, but not fitted with mechanical or thermal
equipment
170 7311 00 Containers for compressed or liquefied gas, of iron or steel
Cloth (including endless bands), grill, netting and fencing, of iron or steel wire;
171 7314
expanded metal of iron or steel
172 7315 Chain and parts thereof, of iron or steel
Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers
173 7318
(including spring washers) and similar articles, of iron or steel
174 7320 Springs and leaves for springs, of iron or steel
Stoves, ranges, grates, cookers (including those with subsidiary boilers for central
175 7321 heating), barbecues, braziers, gas rings, plate warmers and similar non-electric
domestic appliances, and parts thereof, of iron or steel
Table, kitchen or other household articles and parts thereof, of iron or steel; iron or
176 7323 steel wool; pot scourers and scouring or polishing pads, gloves and the like, of iron
or steel
Note: out of the goods provided for under the commodity code 6812 99 900 00, determined by item 151 of this table, a 12% rate
shall only apply to:
a) paper, millboard and felt;
b) compressed asbestos fibre jointing, in sheets or rolls.
2. A 5% rate of import duty shall apply to the customs value of the following goods:
No Code Name of goods
1 0203 Meat of swine, fresh, chilled or frozen
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2 0406 Cheese and curd
3 1806 31 000 00 _ _ Filled
4 1806 32 _ _ Not filled
5 1806 90 - Other
6 3305 Preparations for use on the hair
Pre-shave, shaving or aftershave preparations, personal deodorants, bath
preparations, depilatories and other perfumery, cosmetic or toilet preparations, not
7 3307
elsewhere specified or included; prepared room deodorisers, whether or not
perfumed or having disinfectant properties
Soap; organic surface-active products and preparations for use as soap, in the form
of bars, cakes, moulded pieces or shapes, whether or not containing soap; organic
surface-active products and preparations for washing the skin, in the form of liquid
8 3401
or cream and put up for retail sale, whether or not containing soap; paper,
wadding, felt and nonwovens, impregnated, coated or covered with soap or
detergent
Polishes and creams, for footwear, furniture, floors, coachwork, glass or metal,
scouring pastes and powders and similar preparations (whether or not in the form
9 3405 of paper, wadding, felt, nonwovens, cellular plastics or cellular rubber,
impregnated, coated or covered with such preparations), excluding waxes of
heading 3404
Monofilament of which any cross-sectional dimension exceeds 1 mm, rods, sticks
10 3916 and profile shapes, whether or not surface-worked but not otherwise worked, of
plastics
11 3917 10 - Artificial guts (sausage casings) of hardened protein or of cellulosic materials
--- Seamless and of a length exceeding the maximum cross-sectional dimension,
12 3917 21 100 00
whether or not surface-worked, but not otherwise worked
13 3917 21 900 09 ---- Other
--- Seamless and of a length exceeding the maximum cross-sectional dimension,
14 3917 22 100 00
whether or not surface-worked, but not otherwise worked
15 3917 22 900 09 ---- Other
--- Seamless and of a length exceeding the maximum cross-sectional dimension,
16 3917 23 100 00
whether or not surface-worked, but not otherwise worked
17 3917 23 900 09 ---- Other
18 3917 29 000 09 ---- Other
19 3917 31 000 00 --- Other
---- Other, not reinforced or otherwise combined with other materials, without
20 3917 32 000 00
fittings
21 3917 33 000 09 ---- Other
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22 3917 39 000 09 ---- Other
23 3917 40 000 00 -- Other
Self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics,
24 3919
whether or not in rolls
Other plates, sheets, film, foil and strip, of plastics, non-cellular and not reinforced,
25 3920
laminated, supported or similarly combined with other
26 3921 Other plates, sheets, film, foil and strip, of plastics
27 3925 10 000 00 - Reservoirs, tanks, vats and similar containers, of a capacity exceeding 300 litres
28 3926 10 000 00 - Office or school supplies
29 3926 20 000 00 - Articles of apparel and clothing accessories (including gloves, mittens and mitts)
30 3926 30 000 00 - Fittings for furniture, coachwork or the like
31 3926 40 000 00 - Statuettes and other ornamental items
32 7308 20 000 00 - Towers and lattice masts
33 7308 30 000 00 - Doors, windows and their frames and thresholds for doors
34 8544 11 -- of copper
35 8544 19 000 00 -- Other
36 8544 20 000 00 -- Coaxial cable and other coaxial electric conductors
37 8544 30 000 09 -- Other
3. The goods listed in this Paragraph shall be subject to the following import duty rates (euro/%/vol/HL means that the import
duty amount payable per hectolitre (100 litres) is the import duty rate multiplied by the percentage of alcohol content of the given
good):
Code Name of goods
No Import duty rates
1 2204 10 – Sparkling wine 1.5 euro/l
2 2204 21 – – In containers holding 2 litres or less than 2 litres 0. euro/l
-- in containers holding more than 2 litres, but not more than
3 2204 22 0.2 euro/l
10 litres
4 2204 29 _ _ Other 0.2 euro/l
5 2204 30 – Other grape must 0.2 euro/l
6 2205 10 – – In containers holding 2 litres or less than 2 litres 0.5 euro/l
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7 2205 90 - Other 0.2 euro/l
Other fermented beverages (for example, cider, perry, mead);
mixtures of fermented beverages and mixtures of fermented
8 2206 00 0.5 euro/l
beverages and non-alcoholic beverages, not elsewhere
specified or included
Non-denatured ethyl alcohol of an alcoholic strength by
9 2207 volume of 80 % vol. or higher; ethyl alcohol and other spirits, 3 euro/l
denatured, of any strength
10 2208 20 – Spirits obtained by distilling grape wine or grape marc 1.5 euro/l/HL
11 2208 30 – Whiskies 1.5 euro/l/HL
– Rum and other spirits obtained by distilling fermented
12 2208 40 1.5 euro/l/HL
sugar-cane products
13 2208 50 – Gin and Geneva 1.5 euro/l/HL
14 2208 60 – Vodka 1.5 euro/l/HL
15 2208 70 – Liqueurs and cordials 1.5 euro/l/HL
16 2208 90 – Other 1.5 euro/l/HL
Vinegar and substitutes for vinegar obtained
17 2209 00 0.4 euro/l
from acetic acid
4. Goods temporarily admitted to the customs territory of Georgia, starting from the day of registration of their customs
declaration, for each complete and incomplete calendar month of their stay in the customs territory of Georgia, shall be subject to
3% of the import duty amount that would have been levied on the day of registration of the temporary admission declaration,
during placing such goods under an import procedure. The above amount must be paid by no later than the 15th day of the
month following each given month, and the last payment shall be made on the day of expiry of the transaction of temporary
admission of the goods. The above amount must be paid by no later than the 15th day of the month following each month, and
the last payment shall be made on the day of completing the procedure of temporary admission of goods. The declarant shall have
the right to pay the total due amount as a lump sum.
5. The total sum of the amounts payable under the fourth paragraph of this article (not including penalty) shall not exceed the
import duty amount that would have been levied on the day of registration of the temporary admission declaration, during placing
such goods under an import procedure.
6. The import duty rate of a motor car under heading 8703 of the National Commodity Nomenclature of Foreign Economic
Activities, during its placing under an import procedure, shall be the sum of GEL 0.05 for each cm3 of its engine displacement
and 5% of the import duty amount for each year the motor car’s operation.
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 1898 of 27 December 2013 – website, 30.12.2013
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5129 of 16 October 2019 – website, 23.10.2019
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 198 – Procedure for accrual and paying import duty
1. Import duty shall be accrued according to the customs value of goods, except for the cases provided for in Article 197(3) and (6)
of this Law.
2. Import duty shall be paid according to the procedure established for paying import duty.
3. If, after a motor car specified under Code 8703 of the Foreign Economic Activity National Commodity Nomenclature is placed
under the Release for free circulation procedure, this transport vehicle gets registered under the export procedure and leaves the
territory of Georgia within 180 calendar days, an importer shall be entitled, under the established procedure, to refund for an
import tax paid on the transport vehicle in the amount of 100%.
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6446 of 12 May 2012 – website, 25.6.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 199 – Import duty exemption
The following shall be exempt from import duty:
a) import of goods meant for natural disaster response measures, as well as for humanitarian purposes;
b) import of goods provided for by grant agreements, in the manner determined by an ordinance of the Government of Georgia;
c) import of goods financed with grants or with a concessional loan granted by the state authority of a foreign country and/or an
international organisation, of which at least 25% accounts for a grant element. The Ministry of Finance of Georgia shall calculate
the grant element in accordance with a resolution of the Parliament of Georgia;
d) a natural person’s:
d.a) import (including import by parcel post), once in a calendar day, of food products, not meant for economic activity, of the
total value of up to GEL 500 and of the total weight of up to 30 kg under Groups 02, 04, 06-12, 15-21 and headings 0302-0307,
2201-2202 of the National Commodity Nomenclature of Foreign Economic Activities;
d.b) import, once in 30 calendar days, of goods provided for under the Foreign Economic Activity National Commodity
Nomenclature groups 28 – 97 that are not intended for the economic activity and are valued at up to GEL 500 with the total
weight of up to 30 kg;
d.c) import of 200 cigarettes or 50 cigars or 50 cigarillos, or 200 pieces of tobacco product provided for under the Foreign
Economic Activity National Commodity Nomenclature code 2404 11 000 00, or 10 units of capsules and similar products, or 250
grams of another tobacco product (except for tobacco raw materials), or a collection of sorts of tobacco product specified in this
sub-paragraph if the sum of percentage values (a percentage value in relation to the respective limited amount) of portions of each
sort of tobacco product contained therein does not exceed 100, or totally 50 ml of goods provided for under the Foreign Economic
Activity National Commodity Nomenclature codes 2404 12 000 00 and 2404 19 900 00, which are carried in a baggage and/or
hand luggage during passenger transportation and are not intended for economic activities;
1
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d.c ) import by a passenger in total of 1 litre of alcoholic beverage with 22% and more than 22% alcohol content or of non-
denatured ethanol with 80% and more than 80% alcohol content, or 2 litres of alcoholic beverage with less than 22% alcohol
content, or import of collection of sorts of alcoholic beverage specified in this subparagraph (except for beer and wine) if the sum
of percentage values (percentage value in relation to the respective limited amount) of portions of each sort of alcoholic beverage
(except for beer and wine) contained in the collection does not exceed 100; or import of 4 litres of wine and 16 litres of beer,
which are carried in a baggage and/or hand luggage during a passenger transportation and which are not intended for economic
activities.
d.d) import of goods of up to GEL 15 000 in value, not meant for economic activity under Groups 28-97 (except for Group 87) of
the National Commodity Nomenclature of Foreign Economic Activities, by a person entering Georgia after having stayed abroad
for more than 6 months at a time, and for a diplomatic official recalled from his/her work mission at a Georgian diplomatic mission
or a consular institution abroad as part of a rotation procedure – additionally, import of goods intended for his/her personal use
(one vehicle, refrigerator, computer and TV-set per family);
d.e) import of goods (including furniture, household goods, one vehicle per family) not meant for economic activity, when
entering Georgia for permanent residence (as evidenced by a respective document issued under the established procedure by the
Ministry of Justice of Georgia);
d.f) import, by parcel post, of goods provided for under the Foreign Economic Activity National Commodity Nomenclature groups
28 – 97 that are not intended for the economic activity and are valued at up to GEL 300 with the total weight of up to 30 kg, and
import of 200 cigarettes or 50 cigars or 50 cigarillos, or 200 pieces of tobacco product provided for under the Foreign Economic
Activity National Commodity Nomenclature code 2404 11 000 00, or 10 units of capsules and similar products, or 250 grams of
another tobacco product (except for tobacco raw materials), or a collection of sorts of tobacco product specified in this sub-
paragraph if the sum of percentage values (a percentage value in relation to the respective limited amount) of portions of each sort
of tobacco product contained therein does not exceed 100, or totally 50 ml of goods provided for under the Foreign Economic
Activity National Commodity Nomenclature codes 2404 12 000 00 and 2404 19 900 00, and import of 4 litres of all types of
alcoholic beverage;
d.g) import, by air transport, of goods, not meant for economic activity, of the total value of up to GEL 3 000 and of the total
weight of up to 30 kg under Groups 28 – 97 of the National Commodity Nomenclature of Foreign Economic Activities;
e) import of infant food products and diabetic food products labelled as such for wholesale or retail supply; import of X-ray films,
insulin syringes (needles), glucometers, and diagnostic test systems; in accordance with Article 173(a) of this Code, import of goods
defined by a joint order of the Minister of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social
Affairs of Georgia and the Minister of Finance of Georgia and designated for therapeutic/medical purposes of tobacco addiction;
f) import of goods intended for supply on board performance of international flights and international voyages, and import of fuel,
lubricants and other auxiliary means intended for the delivery on board for the performance of civil flights and special service
(aviation works) within the state border of Georgia;
g) import of equipment and machinery, vehicles, spare parts and materials for performing oil and gas operations provided for by
the Law of Georgia on Oil and Gas;
h) goods seized, confiscated, abandoned and transferred to state ownership and/or a vehicle transferred to the state’s disposal or
ownership in the manner provided for by the legislation of Georgia;
i) import of raw tobacco carried out before 1 January 2028;
j) import of goods in accordance with the requirements of Article 173(w) and (z2-z6) and temporary entry of the goods provided
for by Article 173(z2) and (z3) of this Code;
j1) temporary entry of goods in Georgia for ensuring the performance of commitments (in particular, construction of Baku-Tbilisi-
Ceyhan and Baku-Tbilisi-Erzurum pipelines) provided for by the international agreements of Georgia;
j2) temporary entry of goods completely exempt from customs liabilities under the customs legislation of Georgia;
k) customs procedures/re-export applied to goods (except for import and temporary admission of goods provided for by this article)
under the requirements established by the Customs Code of Georgia, as well as placing goods in a duty-free shop;
l) import of goods manufactured in a Free Industrial Zone from the Free Industrial Zone; the Minister of Finance of Georgia may
establish criteria for considering goods as having been manufactured in a Free Industrial Zone;
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m) import of goods returned in accordance with Article 107 of the Customs Code of Georgia;
n) import, by parcel post (except as provided for by subparagraph d.f) of this article), of goods provided for under the Foreign
Economic Activity National Commodity Nomenclature groups 28–97 that are not intended for the economic activity and are
valued at up to GEL 300 with the total weight of up to 30 kg, and import of 200 cigarettes or 50 cigars or 50 cigarillos, or 200 pieces
of tobacco product provided for under the Foreign Economic Activity National Commodity Nomenclature code 2404 11 000 00, or
10 units of capsules and similar products, or 250 grams of another tobacco product (except for tobacco raw materials), or a
collection of sorts of tobacco product specified in this sub-paragraph if the sum of percentage values (a percentage value in relation
to the respective limited amount) of portions of each sort of tobacco product contained therein does not exceed 100, or totally 50
ml of goods provided for under the Foreign Economic Activity National Commodity Nomenclature codes 2404 12 000 00 and 2404
19 900 00, and as import of 4 litres of all types of alcoholic beverage;
o) import of goods under headings 1704 90 510 00, 2207 10 000 00, 2501 00 310 00, 2501 00 510 00, 2506, 2507, 2508, 2509, 2511,
2522, 2524, 2525, 2526 (except for 2526 20 000 00), 6805 20 000 00 and 6805 30 000 09 of the National Commodity Nomenclature
of Foreign Economic Activities;
p) electric engine vehicles under heading 8703 of the National Commodity Nomenclature of Foreign Economic Activities;
q) import of goods originating in the territory of a state being a party to the International Agreement on Creation of a Free-Trade
Area of 15 April 1994 from such a state, irrespective of the itinerary of such goods (irrespective of passing by such goods of the
territory of a state not being a party to the Agreement, during their movement from the territory of the country of export);
r) goods exempted from the customs obligation provided for by the Customs Code of Georgia in accordance with the conditions
defined by the same Code.
Note:
1. If the amount of an alcoholic beverage and/or tobacco product or of the goods under the Foreign Economic Activity National
Commodity Nomenclature codes 2404 12 000 00 and 2404 19 900 00 imported by a natural person or imported by parcel post
exceeds the limited quantity provided for in subparagraphs d.c), d.f) or n) of this article, the excise tax exemption under this article
shall be applied within the above quantity limits of the goods.
2. A natural person shall gain the right to enjoy the tax privileges under subparagraphs d.c) and d.f) of this article for excise goods
from the age of 18.
3. For the purposes of subparagraphs d.c) and d.c1) of this article, it shall be deemed that the goods are not intended for economic
activities if their import is one-off and they are intended to be used by the passenger personally or by his/her family members,
and/or as a gift. In addition, the import of goods shall be one-off if the import of the goods is carried out not more than once
during one calendar day when they are brought in by an air transport, and in other cases – during 30 calendar days.
Law of Georgia No 4470 of 22 March 2011 – website, 1.4.2011
Law of Georgia No 4720 of 31 May 2011 – website, 10.6.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6439 of 12 June 2012 – website, 22.6.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1046 of 6 September 2013 – website, 23.9.2013
Law of Georgia No 1447 of 4 October 2013 – website, 16.10.2013
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 1897 of 27 December 2013 – website, 30.12.2013
Law of Georgia No 2952 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5444 of 10 December 2019 – website, 13.12.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 1165 of 17 December 2021 – website, 28.12.2021
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 3272 of 15 June 2023 – website, 4.7.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
SECTION IX
LOCAL TAXES
Chapter XXIX – Property Tax
Article 200 – Meanings of concepts for the purposes of this Section
1. Property – taxable property and land.
2. Land – agricultural, non-agricultural and forest land.
3. Agricultural land:
a) arable land (including land under perennial crops);
b) grassland;
c) pastureland;
d) homestead land.
4. Non-agricultural land – any land other than agricultural land.
41. (Deleted – 28.12.2012, No 189).
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5. Agricultural land to be cultivated:
a) non-agricultural land to be transformed into agricultural land. Such lands include:
a.a) virgin land;
a.b) land to be cultivated by means of melioration (irrigation and drainage);
a.c) land under brushwood to be cultivated by felling and uprooting;
a.d) land to be cultivated by terracing slopes;
a.e) land, degraded by mining and construction, to be cultivated by restoration of its agro-biological productivity;
b) low-intensity agricultural land transformed into high-intensity agricultural land (arable land and land under perennial crops),
swampland and salty land.
6. Location of taxable property – the place where the real estate is actually located and movable property is registered, in the
manner provided for by the legislation of Georgia. If there is no movable property place of registration, the location of taxable
property shall be the place where the movable property is actually located.
7. State-owned land – land owned by the State, an autonomous republic or a municipality.
8. Melioration infrastructure – irrigating, draining and dual regulation systems, reservoirs, pumping stations, and individual hydro-
technical structures.
Law of Georgia No 3968 of 10 December 2010 – LHG III, No 74, 24.12.2010, Art. 449
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 5382 of 8 June 2016 – website, 17.6.2016
Law of Georgia No 4854 of 25 June 2019 – website, 2.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 201 – Property tax payer and taxable object
1. A property tax payer shall be:
a) a resident enterprise/organisation:
a.a) on assets, uninstalled equipment, and unfinished construction registered on its balance sheet as fixed assets and/or investment
property, and on its leased out property;
a.b) on real property, a yacht (motor boat), a helicopter, a plane and on another vehicle received (appropriated) within an
enforcement measure for the performance of a contractual obligation;
a.c) on real property, a yacht (motor boat), a helicopter, a plane and on another vehicle purchased by auction, by way of direct sale
or another way within enforcement of payment of a financial liability (except for the sanctions imposed under the criminal and
administrative procedure);
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b) a non-resident enterprise – on property based in the territory of Georgia, provided for by the first paragraph of this article
(including property based in the territory of Georgian transferred under a lease, rent, usufruct or any similar agreement);
c) a natural person:
c.a) on a real estate (including an unfinished construction, building or structure, or a part thereof), yachts (cutters), helicopters,
airplanes, and motor cars specified under Code 8703 of the National Commodity Nomenclature of Foreign Economic Activities
that are owned by him/her;
c.b) on property received by him/her from a non-resident under a lease agreement;
c.c) in the case of carrying out economic activities, on assets, uninstalled equipment, and unfinished construction registered on
his/her balance sheet as fixed assets, as well as his/her leased property.
2. For the purposes of the first paragraph of this article, a person shall be a property tax payer on taxable property owned and/or
used by him/her, registered under the name of a deceased person, except where the property is used under a lease, rent, usufruct
or any similar agreement.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 202 – Property tax rate
1. The annual property tax rate for an enterprise/organisation shall be determined in the maximum amount of 1% of the value of
the taxable property. For the purposes of this paragraph, the value of taxable property shall be the average annual net book value
(calculated according to the average value of assets at the beginning and at the end of a calendar year) that in the cases set forth
below must be increased only in relation to real estate:
a) for assets acquired before 2000 – by 3 times;
b) for assets acquired from 2000 up to 2004 – by 2 times;
c) for assets acquired in 2004 – by 1.5 times;
d) for assets on which the acquisition date is unavailable – in the amount determined by paragraph (1)(a) of this article.
2. The rates referred to in paragraphs (1)(a-d) of this article shall not apply to:
a) an enterprise, if it has the real estate recorded on its balance sheet under the revaluation model and has its financial statement
audited; furthermore, an audited financial statement can be applied for only four years;
b) state-owned enterprises defined by the Government of Georgia.
3. Except as provided for by paragraph (3) of this article, the annual property tax rate for an enterprise/organisation shall be
determined in the maximum amount of 1% of the average annual net book value (calculated according to the average value of
assets at the beginning and at the end of a calendar year) of leased taxable property. For the purposes of this paragraph, the book
value of leased taxable property shall be its value at the moment of its transfer, and for each following year, the net book value of
such property, as if it had not been leased, shall be the value of such property.
31. The annual tax rate on leased taxable property for a leasing company shall be determined, during the entire period of lease
agreement, in the maximum amount of 0.6% of the initial book value of the taxable property at the moment of its first transfer.
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4. (Invalidated – Decision No 2/7/667 of the Constitutional Court of Georgia of 28 December 2017 – website 9.1.2018)
41. In the cases provided for under the procedure approved by the order of the Minister of Finance of Georgia, a tax authority
may, during a tax audit, determine the value of a taxable property of a taxpayer at its market price. This provision shall not apply
to the cases under paragraph 2 of this article. If the market price of the taxable property exceeds its book value:
a) the property tax principal amount shall be assessed to a person on the difference of the taxable property value. Further, a tax
surcharge shall be imposed on the above amount only from the 30th day after the date a notice of tax liability was submitted, and
the above difference shall not be considered as a tax reduction;
b) a person shall use the above market price in relation to the respective taxable property for the following three tax years.
5. The annual tax rate on taxable property of a natural person shall be differentiated according to income earned by the taxpayer's
family during the tax year and determined in the following amounts:
a) for families with income of up to GEL 100 000 – at least 0.05% but not more than 0.2% of the market value of the taxable
property at the end of the tax year;
b) for families with income of GEL 100 000 and more – at least 0.8% but not more than 1% of the market value of the taxable
property at the end of the tax year.
6. For the purposes of this Section, taking into consideration the seventh paragraph of this article, income earned by a natural
person's family during the tax year shall include all income, including income irrespective of tax benefits, particularly:
a) taxable income earned from economic activity except as provided for by paragraph (6)(d);
b) any income, including income not related to economic activity;
c) gross salary;
d) for a person having the status of a small business:
d.a) 25% of income taxable under special treatment;
d.b) taxable income not subject to small business special treatment.
e) for a natural person conducting trade within the market territory:
e.a) 15% of the income gained by selling of goods within the market territory;
e.b) taxable income, which does not belong to the income under subparagraph e.a) of this paragraph.
7. For the purposes of the sixth paragraph of this article:
a) income shall not include:
a.a) value of property received from family members through succession, as a gift or as a result of divorce;
a.b) income received by a natural person (including by a first devisee, as an aggregate of his/her and his/her deviser’s) from sale of
a residential apartment (house) having been in his/her possession for a period of over two years;
a.c) income received from the original sale of property provided for by Article (82)(1)(m) of this Code;
a.d) income of a fixed taxpayer and a person having the status of a micro-business received from such economic activity;
a.e) income exempted from income tax under Article 82 (1)(b1) and (b2) of this Code;
a.f) benefit received by an employee as a result of using an employer’s motor vehicle for his/her personal need;
b) income of a non-resident natural person being a citizen of Georgia shall be determined as per income received at a Georgia
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based source.
8. Tax liability on taxable property shall be defined at the rates applicable on 31 December of the tax year.
9. Property tax of a natural person on taxable property shall be calculated in proportion to the time he/she owned the property
during the tax period.
Law of Georgia No 3882 of 7 December 2010 – LHG III, No 72, 22.12.2010, Art. 428
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2950 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 5387 of 8 June 2016 – website, 24.6.2016
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Decision No 2/7/667 of the Constitutional Court of Georgia of 28 December 2017 – website, 9.1.2018
Law of Georgia No 2327 of 4 May 2018 – website, 11.5.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 203 – Payer of property tax on land and taxable object
The payer of property tax on land shall be a person as of 1 April of the tax year:
a) on land in his/her possession;
b) on land possessed by the state and used or owned by him/her;
c) on a parcel of land in his/her possession and/or use that is registered as property of a deceased person, except for the cases when
the parcel of land is used under a lease, rent, usufruct or similar agreement.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Article 204 – Property tax rate on land
1. The annual basic property tax rates on agricultural land and forest land shall be differentiated according to administrative-
territorial units and land categories, and calculated for 1 ha, in GEL:
a) on arable land (including land under perennial crops) and homestead land:
Basic rate (GEL/ha)
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Name of administrative unit
Arable land and homestead land
1. Tbilisi (other than Tbilisi settlements (villages), Marneuli 100
2. Bolnisi, Gardabani, Tbilisi settlements (villages): Tsavkisi, Kojori,
Tabakhmela, Shindisi, Dideba, Kveseti, Samadlo, Kiketi, Nasagurali, 95
Akhaldaba, Didi Lilo, Varketili
3. Rustavi, Batumi, Gagra, Gali, Gudauta, Gulripshi, Ochamchire, Sukhumi,
94
Tkvarcheli
4. Kobuleti, Khelvachauri, Gurjaani, Dedoplistskaro 87
5. Telavi, Lagodekhi, Signagi 86
6. Kvareli, Gori, Mtskheta, Akhmeta, Dmanisi, Eredvi, Tigvi, Tbilisi
settlements (villages): Digomi, Mshralkhevi, Zahesi Settlement, Gldani,
Didgori, Zurgovana, Telovana, Dzveli Vedzisi, Agaraki, Tkhinvali, from
Gldani Village to Avchala Settlement – garden plots, Giorgitsminda – garden82
plots, garden plots adjacent to Mukhiani, Avshiani Settlement adjacent to
Khevdzmari, Lotkini Settlement – plant nursery, settlement adjacent to Resi,
Tbilisi Sea settlement
7. Kaspi, Tetritskaro, Samtredia 81
8. Sagarejo, Kareli, Khashuri 79
9. Kurta, Tsalka 77
10. Abasha, Zugdidi 77
11. Akhalkalaki, Akhaltsikhe 77
12. Martvili, Senaki, Khobi, Poti 76
13. Ninotsminda 76
14. Akhalgori, Vani, Zestaponi, Lanchkhuti, Ozurgeti 73
15. Bagdati, Terjola, Khoni, Kutaisi 71
16. Tsalenjikha, Tskaltubo, Chkhorotsku 67
17. Sachkhere, Tsageri, Tskhinvali 65
61
18. Ambrolauri, Dusheti, Tianeti, Adigeni, Borjomi
19. Aspindza, Tkibuli, Khulo, Keda 60
20. Shuakhevi, Kharagauli, Chiatura, Lentekhi, Oni, Chokhatauri, Mestia,
56
Stepantsminda, Java
b) for grassland and pastureland:
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Basic rate (GEL/ha)
Name of administrative unit
Grassland Pastureland
1. Abasha, Akhalkalaki, Gori, Batumi, Bolnisi, Gagra, Gali, Gardabani,
Gudauta, Gulripshi, Gurjaani, Dmanisi, Zugdidi, Tbilisi, Tetritskaro, Telavi, 20 16
Lagodekhi, Lanchkhuti, Marneuli, Mtskheta, Ninotsminda, Ozurgeti,
Ochamchire, Rustavi, Samtredia, Senaki, Signagi, Sukhumi, Kutaisi,
Kobuleti, Kvareli, Tsalka, Tskaltubo, Khelvachauri, Khobi, Poti
2. Dedoplistskaro 20 7
3. Adigeni, Aspindza, Akhalgori, Bagdati, Borjomi, Vani, Zestaponi, Terjola, 19 15
Tianeti, Kaspi, Martvili, Sagarejo, Sachkhere, Tkibuli, Kareli, Keda,
Shuakhevi, Chokhatauri, Chkhorotsku, Tsalenjikha, Kharagauli, Khashuri,
Khoni, Khulo, Akhaltsikhe
16 10
4. Ambrolauri, Dusheti, Lentekhi, Mestia, Oni, Kazbegi, Tsageri, Tskhinvali,
Chiatura, Java
5. Akhmeta 16 5
c) for forest land used in agriculture – in the amounts provided for in paragraphs (1)(a) and (1)(b) respectively;
d) the tax rate shall be determined by the decision of the representative body of a municipality, and such rate shall not exceed
150% of the annual basic rate fixed by this paragraph.
11. (Deleted – 28.12.2012, No 189).
2. Property tax rates on non-agricultural land for a particular parcel of land shall be calculated taking into consideration the
location of such parcel of land, according to the following procedure:
a) the basic tax rate shall be fixed at GEL 0.24 per m2 of land per year;
b) by the decision of the representative body of a municipality – Sakrebulo, the appropriate basic rate shall be multiplied by a
territorial coefficient. However, a territorial coefficient shall not exceed 1.5.
3. The land allocated to a person using natural resources under an appropriate licence for the use of natural resources, or in other
form as determined by the legislation of Georgia shall be taxable by a maximum of GEL 3 per 1 ha.
4. Property tax on land tax liability shall be determined at the rates applicable as of 1 April of the tax year.
5. For the purposes of property tax assessment, the list of the information to be submitted to the tax authority by the National
Agency of Public Registry, other registration authorities, and the municipalities, and the procedure for submitting such
information to the tax authority shall be determined by the Government of Georgia.
Law of Georgia No 3882 of 7 December 2010 – LHG III, No 72, 22.12.2010, Art. 428
Law of Georgia No 3968 of 10 December 2010 – LHG III, No 74, 24.12.2010, Art. 449
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
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Law of Georgia No 4854 of 25 June 2019 – website, 2.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 205 – Calculation and payment of property tax
1. The tax period for property tax shall be a calendar year.
2. An enterprise/organisation shall file a property tax return with the tax authority by no later than 1 April of a calendar year, and
pay the property tax within the same time frame, except as provided for by the seventh paragraph of this article. The data on
taxable property shall be recorded in the tax return according to the past tax year and on the taxable land – according to the
current tax year.
3. An enterprise/organisation shall pay property tax for the current tax year in the form of current payment, in the amount of
annual tax paid for past tax year, by no later than 15 June of the current tax year.
4. If the amount of expected property tax liabilities for the current tax year, taking into consideration tax benefits, is reduced by at
least 50%, compared to the past tax year, and the taxpayer gives the tax authority a notice of this by no later than 1 June of the
current year, the taxpayer may reduce the current tax payment or not make a current tax payment.
5. If the submitted actual annual results do not evidence a reduction of expected property tax liabilities by at least 50%, and the
taxpayer has not fully made the current payment during the tax year, then the taxpayer shall pay a penalty under this Code during
the period from the date when the current payment is due to the date when filing a tax return is due.
6. If the tax rate is changed, compared to the past tax period, the taxpayer may make the current payment at the tax rate applicable
for the current year.
7. An enterprise/organisation shall pay property tax on land by no later than 15 November of a calendar year.
8. If a taxpayer enterprise/organisation exists only during a partial calendar year, it shall pay property tax pro rata to such period.
9. If a legal person is founded after the beginning of a calendar year, it shall have no obligation to make a current payment for the
respective tax period. At the same time, the amount of the current payment for the following tax period shall be determined as the
full amount of the annual tax for the past tax year.
10. An entity in the process of winding up (a wound up company) shall, within 5 business days from the registration of
commencement of liquidation process, notify a tax authority in writing of the winding up and shall file a property tax return with
it within the same period of time.
101. A taxpayer shall, within 15 days after entry into legal force of the ruling on recognising as admissible the application for
insolvency and opening the bankruptcy regime delivered by the court under the procedure established by the Law of Georgia on
Rehabilitation and Collective Satisfaction of Creditors, submit to a tax authority the tax returns not submitted according to the
complete/incomplete tax period (periods) before opening of the bankruptcy regime. In addition, a taxpayer shall not submit
property tax returns according to the complete/incomplete tax period (periods) after opening of the bankruptcy regime.
11. A property tax levied on a natural person shall be calculated by the tax authority concerned, based on the filed tax return.
12. A natural person shall file a property tax return with the tax authority no later than 1 November of a calendar year. The data
on taxable property shall be recorded in the tax return according to the past tax year, and on taxable land – according to the
current tax year.
13. A natural person may not file a property tax return if:
a) he/she incurs no tax obligation during the tax period, taking into consideration the privileges under this Code. At the same time,
if the natural person was a property tax declarant for the past tax year, he/she shall give a notice to the tax authority of his/her
decision not to file a tax return in the form approved by the Minister of Finance of Georgia, by no later than 1 November of the
tax year;
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b) the property tax return for the period preceding the tax year has been filed or the tax authority has assessed property tax.
According to the data of the previous tax year, the tax authority shall assess property tax on the taxpayer automatically. In such a
case, a taxpayer shall be deemed to have reported tax and the tax authority shall be deemed to have levied tax liabilities on
him/her, under which the tax liability period under question is equal to the one last reported (assessed). Furthermore, if a tax
return for such periods is later filed, it shall be deemed to be an amended tax return.
131. Where property tax on land is assessed by a tax authority based on the information (data) communicated by the National
Agency of Public Registry, another registration body, and by a municipality body, a person shall be released from the obligation to
file a property tax return on land. In such a case, based on the aforementioned information (data), a tax demand notice shall be
submitted to the person under the procedure determined by the Minister of Finance of Georgia.
14. A natural person shall pay property tax and property tax on land no later than 15 November of a calendar year.
15. The procedure for calculation and payment of property tax shall be defined by the Minister of Finance of Georgia.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6330 of 25 May 2012 – website, 8.6.2012
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Article 206 – Tax exemption
1. According to an object of taxation, the following shall be property tax exempt:
a) a natural person’s taxable property (except land) if the person’s family income received during the year preceding the tax year
does not exceed GEL 40 000;
b) (Deleted – 24.6.2011, No 4963);
c) (Deleted – 24.6.2011, No 4963);
d) traffic roads, power transmission lines, and cable lines of communication networks;
e) property of an organisation, and property leased to the organisation, except land and the property used for economic activity;
f) property used for oil and gas operations (activities) as provided for by the Law of Georgia on Oil and Gas;
g) the part of a state-owned parcel of land that is transferred to a budgetary organisation, except land used for economic activity;
h) land areas of natural and historical monuments protection organisations, where buildings considered by the state as historical,
cultural and/or architectural monuments are situated, if they are not used for economic activity, which does not include the sale of
entry tickets;
i) land occupied by natural parks, botanical and dendrological gardens, municipal cultural and recreational parks, cemeteries,
zoological gardens and/or parks, oceanaria, parks, alleys, protected territories, forest organisations, parks belonging to agencies
open to the public, gardens and forest-gardens, except for parcels of land on such territory used for economic activity;
1
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1 ) plots of land with the status of wind break belt (windbreak field) or a part thereof;
j) city water reservoirs and their water areas; land used for transport and underground communications, if not used for agricultural
produce production and economic activity;
k) land occupied by water reservoirs intended for supplying drinking water to the population, for operation of power stations and
melioration systems and their functioning, and the sanitary, protection and technical areas adjacent to the above facilities;
l) parcels of land used for performing oil and gas operations (activities) provided for by the Law of Georgia on Oil and Gas, if they
are not used for other purposes;
m) parcels of agricultural land, whose topsoil is damaged as a result of a natural disaster (hurricane, hail, drought, flood, landslide,
etc.) by half or more, as evidenced by a certificate issued by the representative body of a municipality;
n) property on the territories defined by the Law of Georgia on Occupied Territories – temporarily, pending resolution of the
conflict and improvement of the economic situation;
n1) land possessed/owned by a person, adjacent to the territories defined by the Law of Georgia on Occupied Territories, that
makes using such parcels of land impossible, as evidenced by a certificate issued by the executive body of a municipality or a
person authorised thereby;
n2) property possessed/owned by a person and parcels of land attached to it, if such a person cannot use such property due to the
property being used as a dwelling for IDPs, and if the property has been registered as a unit of compact (organised)
accommodation of IDPs, as evidenced by a certificate issued by the Ministry of Internally Displaced Persons from the Occupied
Territories, Labour, Health and Social Affairs of Georgia;
o) stated-owned unused grassland, pastureland agricultural land intended for cultivation and spare agricultural land;
p) land used as aerodrome, airport, helidrome and air navigation safety zones and for underground communications, as well as
parcels of land identified for prospective development as ports, if they are not used for economic activity;
q) natural and legal persons, who have received agricultural land to be cultivated – for five years after receiving such land;
r) for families of citizens settled in the territories of abandoned villages, as well as families of citizens settled under state
accommodation measures – on parcels of agricultural land in such territories – for five years after settlement;
s) parcels of agricultural land of up to five hectares owned by a natural person as of 1 March 2004;
Note: The privilege under this subparagraph also applies where a household member or a first/second devisee receives such
property as a gift/through succession, or an agricultural cooperative receives such property from its members (shareholders) as a
contribution (share);
s1) a parcel of agricultural land of up to five hectares owned by an internally displaced person as of 1 January 2011;
t) for primary water users – melioration infrastructure and a part of the land parcel with the melioration infrastructure attached to
it transferred to legal entities under private law under the procedure established by the legislation of Georgia;
u) parcels of land received through privatisation by the persons with disabilities that became disabled as a result of the World War
II and persons equated with them;
v) a parcel of land owned by a person having the status of person permanently residing in a high-mountain settlement, which is
located in a high-mountain settlement;
w) scientific-research, educational, trial-selection, experimental and trial of breed land, used for scientific and educational
purposes, where the activities are financed from the budget;
x) parcels of land used by budget-funded nursing homes/asylums for 60 and over 60 years old persons and/or persons with
disabilities, educational or day care centres for persons (including children) with disabilities and/or children/adolescents without
adequate family support, legal entities under public law – general education institutions (schools) for performing their main
functions; parcels of land used by child fostering institutions, special residential schools, children’s villages, and early and
preschool fostering and educational institutions that provide care and education to children for free, unless they are used for
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economic activity;
y) a parcel of agricultural land, where more than half of the crops have been destroyed as a result of natural disaster (hurricane,
hail, drought, flood, landslide, etc.) or other force-majeure, as evidenced by a certificate issued by a person (persons) authorised by
the executive body of a municipality;
z) property within a Free Industrial Zone;
z1) biological assets;
z2) property received by leasing from a Georgian resident;
z3) property, except land used for medical activities, which is in the possession of or leased to medical institutions;
z4) parcels of land used for medical activities, attached to medical institutions;
z5) property related to hotel services of an entrepreneur in a tourist zone until 1 January 2026;
z6) movable property in the possession of a person engaged in an activity provided for under Code 01 (agriculture) of the Foreign
Economic Activity National Commodity Nomenclature, as well as movable property leased to such person, that such person uses
in the same activity;
z61) property (except land) owned by an agricultural cooperative, used in agricultural activity and movable property leased to it
for the same activity before 1 January 2028;
z7) property (including land) used in general educational activities by a Legal Entity under Public Law – a public school,
authorised under the procedure established by the Minister of Education, Science and Youth of Georgia;
z71) a taxable object (parcel of land) determined pro rata to the space co-owned by a natural person in a residential apartment
house;
z72) parcels of land attached to residential houses and/or garages, located within the administrative boundaries of the
municipalities, within the limited space determined by the representative body of a municipality – Sakrebulo;
z73) goods under heading 8903 of the National Commodity Nomenclature of Foreign Economic Activities;
z74) property of a person under the bankruptcy regime under the procedure established by the Law of Georgia on Rehabilitation
and Collective Satisfaction of Creditors;
z75) real estate gratuitously transferred by a state body and/or a municipality, which is owned/used by a state-founded higher
education institution and used for educational activities and/or for providing services related to educational activities;
z76) the property owned by a high-mountain settlement enterprise and located in that high-mountain settlement – for 10 calendar
years after the granting of the status (including the calendar year in which the status was granted).
2. The established tax privileges shall not apply to a parcel of land (or part of it) transferred by a person to another person by lease,
usufruct, rent or any other similar form, and/or to structures or buildings (or part of them) transferred by an
enterprise/organisation in the same form, except when the real estate is transferred by a state-founded higher education institution
and the transferred real estate is used for educational activities and/or for providing services related to educational activities.
3. If after the expiry of the term for filing a tax return a person transfers a parcel of land by lease, usufruct, rent or any other
similar form, no tax privilege shall apply to such person. At the same time, a person shall be obliged to file a tax return with the tax
authority by the end of the accounting year and pay the tax as per the tax notice.
Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469
Law of Georgia No 4142 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 515
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 817 of 12 July 2013 – website, 5.8.2013
Law of Georgia No 1873 of 26 December 2013 – website, 28.12.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2540 of 26 July 2014 – website, 6.8.2014
Law of Georgia No 2953 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 4037 of 16 July 2015 – website, 28.7.2015
Law of Georgia No 5382 of 8 June 2016 – website, 17.6.2016
Law of Georgia No 5372 of 8 June 2016 – website, 24.6.2016
Law of Georgia No 5491 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 499 of 23 March 2017 – website, 27.3.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 3109 of 5 July 2018 – website, 11.7.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 342 of 16 March 2021 – website, 18.3.2021
Law of Georgia No 809 of 22 July 2021 – website, 26.7.2021
Law of Georgia No 970 of 2 November 2021 – website, 5.11.2021
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 845 of 26 June 2025 – website, 3.7.2025
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
SECTION X
(Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
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Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XXX – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 207 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2071 – (Deleted)
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 208 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 209 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XXXI – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 210 – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
http://www.matsne.gov.ge 20000000005001016012
Article 211 – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 212 – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 213 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XXXII – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 214 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2141 – (Deleted)
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 215 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 216 – (Deleted)
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 217 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 218 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 219 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6439 of 12 June 2012 – website, 22.6.2012
Law of Georgia No 6550 of 22 June 2012 – website, 29.6.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 220 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 221 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 222 – (Deleted)
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XXXIII – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 223 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6446 of 12 May 2012 – website, 25.6.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 224 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2241 – (Deleted)
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
http://www.matsne.gov.ge 20000000005001016012
Article 225 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 226 – (Deleted)
Law of Georgia No 4720 of 31 May 2011 – website, 10.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2261 – (Deleted)
Law of Georgia No 4547 of 19 April 2011 – website, 5.5.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XXXIV – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 227 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 228 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 229 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6446 of 12 May 2012 – website, 25.6.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
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Article 230 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 231 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 232 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 233 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 234 – (Deleted)
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 235 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 236 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
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Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 237 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
SECTION XI
TAX COLLECTION COMPLIANCE SECURITY MEASURES
Chapter XXXV – Tax Collection Compliance Security Measures
Article 238 – Securing tax collection compliance by the tax authority
1. To secure tax collection compliance, the tax authority may apply the following measures:
a) imposing a tax lien/mortgage;
b) levying a tax on a third person;
c) seizing property;
d) selling seized property;
e) presenting a collection order to a bank account;
f) collecting cash from the cash register of the taxpayer;
g) (deleted).
2. The tax authority shall select the order of priority of apply tax collection compliance security measures, unless otherwise
provided for by this Code.
3. The procedure for apply the measures provided for by this Chapter shall be determined by an order of the Minister of Finance of
Georgia.
4. If the Revenue Service and the registration authority and/or a banking institution have signed an agreement on electronic
exchange of information (including information on tax collection compliance security measures), the measures provided for under
this Chapter may be applied using electronic technologies, subject to the terms and conditions stipulated by such an agreement.
5. When conducting proceedings under the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors, the
measures provided for under this article shall be applied against an enterprise only for enforcing payment of an outstanding tax
liability having arisen after the entry into legal force of the court decision on recognising as admissible the application for
insolvency.
6. Any measure provided for under this Chapter, that has commenced to secure tax collection compliance, shall be cancelled upon
cancellation of the tax liability, unless otherwise provided for by this Code.
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7. The measures provided for under this Chapter may be cancelled:
a) by the decision of the Minister of Finance of Georgia or the head of the Revenue Service;
b) where so provided for by the eighth paragraph of this article – by the decision of the head of the tax authority. At the same
time, the head of the tax authority cannot cancel a measure provided for under Article 239 of this Code, if the person’s assets are
liened/mortgaged in order to postpone the payment of any outstanding tax liability.
8. By the decision of the head of a tax authority, payment of an acknowledged outstanding tax liability may be postponed for a
maximum of three years, if, to secure the collection compliance of a taxpayer, a surety agreement has been signed or a bank
guarantee or insurance policy has been provided, and/or the taxpayer’s property, the value of which ensures payment of the
acknowledged tax liability, has been liened/mortgaged. Postponing payment of the acknowledged outstanding tax liability shall
not suspend the accrual of penalties.
81. By decision of a tax authority, collection of an acknowledged outstanding tax liability may be postponed for a maximum of one
year without presentation of a guarantee specified in paragraph 8 of this article, provided the acknowledged outstanding tax
liability does not exceed GEL 50 000.
9. An agreement on postponing the payment of an acknowledged tax liability shall be signed with a taxpayer, which shall reflect
the terms and conditions for payment of the acknowledged tax liability.
10. If the taxpayer fails to fulfil the terms and conditions of the agreement on postponing the payment of an acknowledged tax
liability, the decision of a tax authority on postponing the payment of the acknowledged outstanding tax liability shall be
cancelled.
11. (Deleted – 6.3.2024, No 4056).
111. If a person wishes to discharge the acknowledged tax liabilities (to the extent the tax lien/mortgage is imposed on his/her
property) for securing the payment of which the tax lien/mortgage is imposed on his/her property on the basis of Article 239(5) of
this Code, it shall be possible, under the procedure and on conditions determined by paragraphs 8-10 of this article, to conclude an
agreement (a schedule) with him/her regarding the aforementioned tax liabilities. In this case, the measures in relation to the
above property provided for by Articles 241 and 242 of this Code may be withdrawn by decision of the head of the tax authority.
12. When applying the measures provided for by this article against a central security depositary licensed on the basis of the
legislation of Georgia, against a stockbroker, a banking institution as a stockbroker, a brokerage firm, the Legal Entity under Public
Law – the Pension Fund of Georgia, a central depositary licensed on the basis of the legislation of a foreign country, a financial
institution licensed on the basis of the legislation of a foreign country within carrying out brokerage activities on a securities
market, a notary or a payment service provider as a taxpayer, such measures may not be enforced against the assets (securities and
monetary funds) that it possesses in favour of its clients (in the case of the Legal Entity under Public Law – the Pension Fund of
Georgia, participants/beneficiaries of pension) and/or that are not its property and are the assets of its client. Such assets of the
client must be held separately from own assets, in accordance with the legislation of Georgia.
121. The tax collection compliance security measures under this Chapter shall not apply to financial collateral (object of financial
collateral) provided for by the Law of Georgia on Financial Collateral, Mutual Deduction and Derivatives.
122. The tax collection compliance security measures provided for by this Chapter, except for those indicated in Article 243 of this
Code shall not apply to the system participant’s settlement account referred to in the Law of Georgia on Payment System and
Payment Services.
123. On the request of the National Bank of Georgia, the tax collection compliance security measures provided for by this Chapter
shall immediately be suspended for or shall not apply to a commercial bank under the resolution regime in accordance with the
Organic Law of Georgia on the National Bank of Georgia and the Law of Georgia on Commercial Bank Activities for a period set in
the request of the National Bank of Georgia, which must not exceed 90 days. The National Bank of Georgia shall notify a tax
authority if the resolution regime ends earlier than the period set in the request of the National Bank of Georgia, and the tax
authority shall have the right to resume the tax collection compliance security measures.
124. The tax collection compliance security measures provided for by this Chapter shall not apply to the assets included in the
consolidation of security assets defined in Article 2(1)(b) of the Law of Georgia on Mortgage-backed Bonds.
125. When applying measures provided for by this article against a service rendering person defined by Article 20(1) of the Law of
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Georgia on Transformation into Securities, the said measures may not be applied towards financial resources to be designated for a
special purpose vehicle for securitisation and that are kept separate by the service rendering person from its own assets and from
those of other clients, under Article 20(2) of the same Law.
126. The measures of securing the enforcement of payment of tax arrears provided for by this Chapter shall apply to the assets of a
sub-fund of an umbrella fund defined by the Law of Georgia on Investment Funds only if the measures aim to secure the
enforcement of payment of the tax arrears that have originated in relation to the activity of the said sub-fund. Such assets must be
recorded separately from another sub-fund (other sub-funds) of an umbrella fund, under the legislation of Georgia.
127. The measures of securing the enforcement of payment of tax arrears provided for by this Chapter shall apply to the assets of a
division of a special purpose vehicle for securitisation (securitisation division) set up in accordance with the Law of Georgia on
Transformation into Securities only if the measures aim to secure the enforcement of payment of the tax arrears that have
originated in relation to the activity of the said securitisation division. Such assets must be recorded separately from another
division (other divisions) of the special purpose vehicle for securitisation, under the legislation of Georgia.
128. The measures of securing the enforcement of payment of tax arrears provided for by this Chapter shall not apply to the
pension assets defined by the Law of Georgia on Funded Pension.
13. (Deleted).
14. The tax collection compliance security measures provided for by this Chapter shall not apply to the pension assets provided for
by the Law of Georgia on Voluntary Private Pension.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 6312 of 25 May 2012 – website, 12.6.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 649 of 21 April 2017 – website, 10.5.2017
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1898 of 23 December 2017 – website, 11.1.2018
Law of Georgia No 5658 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 5677 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 2113 of 29 November 2022 – website, 16.12.2022
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3723 of 16 November 2023 – website, 7.12.2023
Law of Georgia No 3940 of 15 December 2023 – website, 27.12.2023
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Law of Georgia No 4056 of 6 March 2024 – website, 14.3.2024
Law of Georgia No 4324 of 27 June 2024 – website, 12.7.2024
Article 239 – Tax lien/mortgage
1. Imposing a tax lien/mortgage shall be the right of the State to secure payment of outstanding tax liabilities from the property of
a taxpayer or any other liable person.
2. The right to register a tax lien/mortgage shall arise when the tax liability arises and upon registration with the registration
authority, and shall extend, within the scope of the tax liability, to any property owned by and/or recorded on the balance sheet
(other than property held under a lease) of the person, including the property acquired after the tax liability arose. Imposition of a
tax lien/mortgage may be exercised where provided for by Article 265 of this Code.
3. A notice on exercising the right to impose a tax lien/mortgage shall be sent to the taxpayer/liable person and to the relevant
registration authority that shall be obliged to register the tax lien/mortgage no later than the day following the day of receipt of
such notice.
4. As a result of selling property under a tax lien/mortgage, as provided for by the legislation of Georgia, all the real rights arising
after the registration of the tax lien/mortgage shall be cancelled, while any other tax lien/mortgage registered before the
registration of the tax lien/mortgage shall remain in force.
5. If the property under a tax lien/mortgage is sold or in any other way transferred to any other holder without cancelling the tax
lien/mortgage, the tax lien/mortgage shall continue to apply to such property with respect to its new holder. Such property shall
be seized and sold in accordance with Articles 241 and 242 of this Code.
6. If any tax lien/mortgage on a person’s property was registered in favour of banking institutions, microfinance organisations,
insurance companies, international financial institutions and financial institutions of developed countries, defined by Article (1)(e)
of the Law of Georgia on Commercial Bank Activities, prior to the registration of the tax lien/mortgage, and such property is sold,
the proceeds of such sale shall first clear the claims of such financial institutions to the extent of liabilities arising prior to the
registration of the tax lien/mortgage, and after that the tax liability shall be claimed for. A tax lien/mortgage shall not apply to a
new owner of such property. If the remaining amount is not sufficient for the full payment of the tax liability, any outstanding tax
liability shall remain in force for a person whose property was liened/mortgaged.
61. If, before registration of any tax lien/mortgage on a person’s property, a commercial bank, a microfinance organisation, an
insurance company or a financial institution of developed countries defined by Article (1)(e) of the Law of Georgia on Commercial
Bank Activities transfers the claim secured by the tax lien/mortgage to a special purpose vehicle for securitisation set up in
accordance with the Law of Georgia on Transformation into Securities and such property goes for sale, proceeds of such sale shall
first clear the claims of the special purpose vehicle for securitisation to the extent of liabilities arising prior to the registration of
the tax lien/mortgage, and after that the tax liability shall be claimed for. A tax lien/mortgage shall not apply to a new owner of
such property. If the remaining amount is not sufficient for the full payment of the tax liability, any outstanding tax liability shall
remain in force for a person whose property was liened/mortgaged.
7. The order of priority of a tax lien/mortgage claim after completion of the proceedings under the Law of Georgia on
Rehabilitation and Collective Satisfaction of Creditors shall be defined in accordance with the same procedure that existed before
commencement of the proceedings under the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors.
8. (Deleted – 28.12.2012, No 189).
9. Tax lien/mortgage shall be cancelled:
a) if the liened/mortgaged property has been sold by the competent authority identified under Article 242 of this Code for the
purpose of clearing the tax liability;
b) if by written consent of the tax authority the taxpayer has sold the property or a part of it and directed the proceeds in full
towards clearing the outstanding tax liability;
c) if the property has been abandoned to the state according to procedures provided for by the legislation of Georgia;
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d) if the liened/mortgaged property is sold under the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors;
d1) in the cases provided for by Article 401(5) of the Law of Georgia on Enforcement Proceedings;
e) if no tax liability arises as a result of applying the procedures provided for by Article 265 of this Code;
f) (Deleted – 28.12.2012, No 189);
g) in others cases provided for by this Code.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5169 of 28 October 2011 – website, 11.11.2011
Law of Georgia No 5978 of 30 March 2012 – website, 19.4.2012
Law of Georgia No 6145 of 8 May 2012 – website, 17.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 3940 of 15 December 2023 – website, 27.12.2023
Law of Georgia No 4056 of 6 March 2024 – website, 14.3.2024
Article 240 – Levying tax on a third person
1. For the purpose of enforcing payment of a taxpayer’s acknowledged overdue tax liability, the tax authority may give a Tax
Notice to a third person and enforce payment of tax from his/her property, if the taxpayer’s property is so small that applying
other tax liability security measures by the tax authority has not ensured payment of an acknowledged overdue tax liability, and a
court decision or any other evidence has established that the third person has an outstanding tax liability that is due.
2. Upon fulfilment of the Tax Notice in full or in part, the taxpayer’s tax liability shall be cancelled or reduced respectively.
3. If the third person fails to satisfy the Tax Notice in 30 days after its receipt, the tax authority may apply the measures provided
for by paragraphs (1)(a) and (c)-(f) of Article 238 of this Code in relation to such person.
31. A tax authority may, except as provided for by paragraphs 2-3 of this article, carry out measures under Article 238(1)(a) and (c-
f) of this Code against an authorised person selling the goods provided for by Article 1611(1) and (2) of this Code if this person
fails to fulfil the obligation to pay the amount of VAT under the same article to the budget.
4. The tax authority shall select the order of priority of carrying out tax collection compliance security measures.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 241 – Seizure of property
1. The tax authority, without any court decision, may seize any assets owned by and/or recorded on the balance sheet (other than
property held under lease) of a person to the extent of the amount necessary to secure the acknowledged outstanding tax liability.
Regarding the seizure of assets, an authorised person of the tax authority shall issue an individual administrative-legal act.
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11. Under the contract between the tax authority and the National Bureau for Enforcement, the tax authority may delegate to the
National Bureau for Enforcement carrying out procedures for seizure of the taxpayer’s property.
2. For the purposes of this Code, the seizure of property means taking inventory of the property of a person, and prohibiting the
disposal of such property (any form of alienation of the property by the person, pledge, mortgage, usufruct, easement,
encumbering with building leasehold, lending, signing tenancy or lease agreements, transfer to any other person in temporary or
permanent possession by the person). A representative of the tax authority shall record seized items in a Property Seizure Record.
21. In the cases provided for by paragraph (11) of this article, the tax authority shall send an individual administrative-legal act on
seizure of the taxpayer’s property, to ensure the seizure of the property of the person indicated in the act, to the National Bureau
for Enforcement that performs, in the manner provided for by the legislation of Georgia, procedures for seizure of the property.
3. By written consent of the tax authority, a person may dispose of seized property, if the proceeds are fully put towards satisfying
the outstanding tax liability. If property or any part of it has been sold with the consent of the tax authority and the proceeds have
been fully put towards satisfying the outstanding tax liability, the seizure of the property shall be cancelled.
4. A Property Seizure Record shall be signed by a representative of the tax authority/National Bureau for Enforcement, the
depositary of property, the taxpayer/liable person and other persons present at the seizure of the property. If such persons refuse to
sign, a relevant note shall be made in the Record.
5. The tax authority/the National Bureau for Enforcement shall promptly send a Property Seizure Record to the registration
authority concerned.
6. An expert or an auditor may be contracted to evaluate the seized property.
7. If there is a risk that a person may transfer property in a way that will complicate or prevent enforcement of payment of the
outstanding tax liability, the tax authority may promptly seize the property (including bank accounts) irrespective of whether such
tax liability has or has not been acknowledged. In such a case, seizure may be performed by affixing a seal. Under a contract with
the National Bureau for Enforcement, the tax authority may assign the National Bureau for Enforcement to perform the seizure of
and the respective procedures for affixing a seal to the property (other than bank accounts).
8. In the case provided for in paragraph 7 of this article, within 48 hours after performing procedures for seizure of property, the
tax authority or the National Bureau of Enforcement shall file a motion to a court for confirmation of the seizure of a person’s
property (including bank accounts). The court shall, within five days, consider the motion by oral hearing and deliver a ruling on
granting the motion in full or in part or on refusing to grant the motion. Failure of a party to appear or the impossibility to invite a
party to a court hearing shall not result in deferring consideration of the motion of the tax authority or the National Bureau of
Enforcement. If, within that period, the tax authority or the National Bureau of Enforcement fails to file a motion to the court or
the court fails to deliver a ruling on the confirmation of seizure of property (including bank accounts), the seizure shall be deemed
cancelled, and any seal affixed to the property shall be removed.
9. Seizure of property shall be cancelled in the cases provided for by Article 239(9) of this Code.
10. Seizure of a bank account shall mean the limitation by the tax authority of a person’s right to dispose of the funds available in
or transferred to his/her bank account to the extent of the amount of the seizure, except for the case when such person pays the
tax, fines and penalty amounts payable under this Code to the budget, or pays state duties payable on the cases under consideration
at the Constitutional Court of Georgia or a general court. The decision of the tax authority on seizure of a taxpayer’s bank account
shall indicate the person’s identification number and the payable amount.
101. A liquidator of a banking institution, a special manager of a commercial bank, or a liquidator of a payment service provider
registered under the Law of Georgia on Payment Systems and Payment Services may, under the Law of Georgia on Commercial
Bank Activities, the Law of Georgia on Payment Systems and Payment Services and the Law of Georgia on Microbank Activities,
transfer the seized accounts to another banking institution, another registered payment service provider and/or the National Bank
of Georgia.
102. Where so provided for by the Law of Georgia on Holding Dematerialised Securities, Law of Georgia on Securities Market,
Law of Georgia on Collective Investment Undertakings, Law of Georgia on Commercial Bank Activities and Law of Georgia on
Microbank Activities, a liquidator or a special manager may transfer the seized securities accounts unchanged to another account
keeper or a financial institution with relevant authorisation.
11. In the case provided for by paragraph 10 of this article, the person shall not have the right to open a bank account with the
same or any other banking institution.
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Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Decision No 2/8/734 of the Constitutional Court of Georgia of 28 December 2017 – website, 9.1.2018
Law of Georgia No 1898 of 23 December 2017 – website, 11.1.2018
Law of Georgia No 2640 of 27 June 2018 – website, 6.7.2018
Law of Georgia No 5658 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 1808 of 9 September 2022 – website, 23.9.2022
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 3723 of 16 November 2023 – website, 7.12.2023
Article 242 – Sale of seized property
1. The court shall consider an application of the tax authority or the National Bureau for Enforcement (if the procedures for
seizure of property are performed by the National Bureau for Enforcement) to sell a person’s seized property or abandoning it
directly to the state in the manner provided for by the Administrative Procedure Code of Georgia. The tax authority/the National
Bureau for Enforcement may require abandoning of a person’s seized property directly to the state only if the acknowledged
outstanding tax liability equals or exceeds the market value of the property.
2. If any outstanding tax liability is acknowledged as a result of a public notice, the tax authority shall apply to court to sell the
person’s seized property 10 days after expiry of the term for appealing the Tax Notice.
3. The sale of a debtor’s liened/mortgaged and seized property by auction shall be performed by the relevant authority – the
National Bureau for Enforcement – a legal entity under public law within the jurisdiction of the Ministry of Justice of Georgia,
based on the order of a judge in the manner provided for by the Law of Georgia on Enforcement Proceedings, except for property
referred to in the fourth paragraph of this article, the sale of which shall be performed by the tax authority.
4. The sale of any seized perishable goods can be performed immediately. Perishable goods shall be seized and sold without a court
decision.
5. The proceeds of the sale of property shall primarily cover:
a) the enforcement fee and enforcement expenses – if the property is sold by the National Bureau for Enforcement;
b) costs related to seizing and keeping/storing property, and in the case of sale of property referred to in the third paragraph of this
article – costs related to the sale of such property as well;
c) payable tax;
d) payable fine and penalty.
6. Funds remaining after the amounts that were to be covered primarily with the proceeds from sale of property have been paid
shall be returned to the taxpayer within five working days.
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7. The appropriate tax authority shall be immediately notified of the sale of a debtor’s seized property in the manner provided for
by the third paragraph of this article and be furnished with the documents evidencing the sale of such property, after which the
tax authority shall perform the appropriate measures provided for under this Code in relation to the taxpayer (debtor) and the new
owner of the sold property.
Law of Georgia No 3969 of 10 December 2010 – LHG III, No 72, 22.12.2010, Art. 433
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Article 243 – Presenting a collection order to a bank account
1. In the cases provided for by this Code, the tax authority may, to the extent of the acknowledged outstanding tax liability, charge
the amounts of taxes, penalties and fines against his/her bank account (other than deposit (time deposit) accounts) by a collection
order and transfer the amounts to the respective state budget accounts.
2. The decision of a tax authority on writing off the amount of a tax and a sanction (including a customs sanction) from a person’s
bank account shall be forwarded to this person electronically.
3. A collection order of the tax authority shall state the person’s identification number and the amount to be charged.
4. If the acknowledged outstanding tax liability is increased or decreased, the tax authority may make an appropriate amendment
in the collection order presented to the banking institution.
5. A liquidator of a banking institution, a special manager of a commercial bank, or a liquidator of a payment service provider
registered under the Law of Georgia on Payment Systems and Payment Services may, under the Law of Georgia on Commercial
Bank Activities, the Law of Georgia on Payment Systems and Payment Services and Law of Georgia on Microbank Activities,
transfer the accounts for which a collection order has been submitted by a tax authority to another bank institution, another
registered payment service provider and/or the National Bank of Georgia.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 1898 of 23 December 2017 – website, 11.1.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5658 of 20 December 2019 – website, 31.12.2019
Law of Georgia No 1808 of 9 September 2022 – website, 23.9.2022
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 244 – Collection of cash from the person’s cash desk
1. If the measure provided for by Article 243 of this Code is insufficient to clear any acknowledged outstanding tax liability, the
tax authority may, without a judge's order, collect cash from the cash desk (place where cash is kept) of the taxpayer/other liable
person to the extent necessary to discharge the acknowledged outstanding tax liability.
2. The cash collected from the cash desk or other premises of the person shall be deposited in the relevant state budget account
with the banking institution on the same day, and if impossible – on the nearest business day.
3. The measure provided for by this article cannot be performed in the person’s dwelling without a judge’s order.
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Article 245 – (Deleted)
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Article 246 – Straw man for a taxpayer
1. A person shall be considered to be a straw man for a taxpayer if this person is used for the evasion of measures of securing the
enforcement of payment of the expected or existing tax arrears.
2. A person shall be recognised as a straw man for a taxpayer on the basis of a court judgment.
3. The court shall review a motion of a tax authority on recognising a person as a straw man for a taxpayer under the procedure
established by the Administrative Procedure Code of Georgia.
4. A tax authority shall have the right, along with filing a motion on recognising a person as a straw man for a taxpayer with a
court, to impose a tax lien/mortgage on the property of this person within the amount of the taxpayer’s tax arrears. If the court
denies the motion of the tax authority on recognising the person as a straw man for the taxpayer, the tax lien/mortgage shall be
cancelled.
5. A tax authority shall have the right, for the enforcement of payment of the taxpayer’s acknowledged tax arrears, to apply
measures of enforcing the payment of the tax arrears provided for by this Chapter against the straw man for the taxpayer.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 247 – (Deleted)
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 248 – Securing discharge of tax liability by a taxpayer
1. A taxpayer may use the following means of securing discharge of tax liabilities:
a) surety;
b) bank guarantee;
c) insurance policy.
2. To secure payment of import and export duties, the Minister of Finance of Georgia may define other types of guarantee.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Article 249 – Surety
1. Under a surety contract, a surety jointly undertakes to fully cover the taxpayer’s tax arrears if the taxpayer fails to pay the tax
arrears within the set time limit. A surety shall be executed on the basis of an agreement between the surety and the tax authority.
2. A surety can be either a legal person, or a natural person. Several persons may be sureties for the same obligation. In such a case,
they shall be responsible as joint debtors, even if they have not undertaken the surety jointly.
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3. If the surety fails to fulfil his/her obligations, the tax authority may request that any party to the surety agreement pay the tax
arrears of the taxpayer and, for the enforcement of their payment, apply measures of securing the enforcement of payment of tax
arrears provided for by this Code.
4. The legal relations defined by this article shall be governed by provisions of the civil legislation of Georgia, unless otherwise
provided for by the tax legislation of Georgia.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 250 – Bank guarantee
1. At the request of a taxpayer, under a bank guarantee, a banking institution (guarantor) undertakes a written obligation to cover
the taxpayer’s outstanding tax liability to the extent of the obligation undertaken, based on the written application of the tax
authority.
2. A bank guarantee cannot be revoked by the guarantor.
3. If the guarantor fails to fulfil his/her obligations, the tax authority may request that any party to the bank guarantee agreement
pay the tax arrears of the taxpayer and, for the enforcement of their payment, apply measures of securing the enforcement of
payment of tax arrears provided for by this Code.
4. The legal relations defined under this Code shall be governed by provisions of the civil legislation of Georgia, unless otherwise
provided for by the tax legislation of Georgia.
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 251 – (Deleted)
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 252 – Writing off tax liabilities
1. An outstanding tax liability shall be written off according to procedures established by the Minister of Finance of Georgia:
a) if established that a person has no property and/or assets;
b) in cases provided for by Articles 57 and 58 of this Code;
c) if a person has not performed tax reporting for the last 6 calendar years and the legislation of Georgia no longer provides for its
legal form;
d) in the case of liquidation of a budgetary organisation;
e) if a legal entity is removed from the Register of Entrepreneurs and Non-entrepreneurial (Non-commercial) Legal Entities and
the Register of Citizens’ Political Alliances (Parties) under the procedure established by the legislation of Georgia;
f) where so provided for in Article 106(4) of the Law of Georgia on Rehabilitation and Collective Satisfaction of Creditors, when
the purchaser (purchasers) of insolvency mass of an entrepreneurial legal entity under private law as an integrated property
complex is (are) registered as the sole partner (partners) of this enterprise.
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11. Except as provided for by the first paragraph of this article, outstanding tax liability may be written off a budgetary
organisation, in the manner provided for by the Government of Georgia, by the decision of the Government of Georgia.
2. If a person, whose outstanding tax liability has been written off, continues economic activity, accrual of tax liabilities and/or
penalties previously written off against such a person shall be renewed, except as provided for by paragraph (1)(f) of this article.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5144 of 27 May 2016 – website, 4.6.2016
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Article 253 – Procedure for discharging acknowledged tax liabilities
Acknowledged tax liabilities shall be discharged in the following order:
a) payable amount of tax;
b) fine;
c) penalty interest.
2. The procedure for discharging acknowledged tax liabilities shall be established by an order of the Minister of Finance of Georgia
based on the order specified in paragraph 1 of this article.
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Article 254 – Securing the tax arrears during the pendency of a tax dispute
1. For the purposes of this article, the disputed tax arrears shall be the amount of a tax and/or a sanction (including a customs
sanction) assessed to a person, which has not been recognised and has been appealed under the procedure established by this Code.
2. The obligation to discharge the disputed tax arrears shall be deemed suspended from the day of commencement of a tax dispute
till its completion.
3. For securing the tax arrears, a tax authority may seize:
a) the property of a person;
b) the bank accounts of a person within the amount of the tax arrears, in cases provided for in Article 241(7) and (8) of this Code
and under the procedure established by the same paragraphs.
4. During the pendency of a tax dispute, the measure under paragraph 3 of this article against a person shall not be applied and the
one already applied shall be cancelled if:
a) a surety agreement has been signed, a bank guarantee or an insurance policy has been provided in accordance with this Code to
secure a person’s tax arrears during the pendency of a tax dispute;
b) a person’s assets, the value of which secures payment of the tax arrears, have been tax liened/mortgaged.
5. All measures initiated and means submitted to secure the disputed tax arrears shall be deemed cancelled if the tax dispute is
resolved in favour of the taxpayer.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
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Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
SECTION XII
TAX CONTROL
Chapter XXXVI – General Provisions
Article 255 – General provisions related to tax control
1. The general provisions related to tax control, set out in this Section, shall apply to all persons unless otherwise provided for by
the tax legislation of Georgia.
2. Only a tax authority shall perform tax control of a person’s activity. Other controlling and law-enforcement bodies shall be
prohibited from performing tax control of a person’s activity.
3. Tax control procedures shall not reasonably disturb the ordinary course of activity of a person and shall not suspend his/her
activity.
4. The types of tax control shall be current control and tax audit.
5. Tax control shall be performed without a judge’s order, except as expressly provided for by this Code.
6. Without a judge’s order, it shall be prohibited to re-audit an already audited matter of a person’s activity, except matters for
which a person files an adjusted tax return for an already audited period.
7. If necessary, a specialist/expert may be contracted to perform a particular act of tax control.
8. The court shall consider an application of the tax authority regarding a matter defined by this article in the manner provided for
by the Administrative Procedure Code of Georgia.
9. (Deleted – 13.5.2016, No 5092).
10. Tax control shall be performed without a judge’s order, when conducted on a taxpayer’s initiative.
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Chapter XXXVII – Current Control Procedures
Article 256 – General provisions related to current control of a person’s activity
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1. The procedures of current control of a person’s activity shall be implemented without any prior notice based on an order of an
authorised person of the tax authority.
2. The tax authority may use technical means for recording current control procedures.
3. Current control over a person’s activity shall be performed during working hours and/or during the actual work of such a
person.
4. The person may attend current control procedures applied in relation to such person.
5. In the cases provided for by this Code, the findings of current control procedures shall be reflected in a report to be signed by an
authorised person of the tax authority implementing current control procedures and the taxpayer/taxpayer’s representative, as well
as by any other person participating in such procedures. If a person refuses to sign the report, an appropriate note shall be made in
the report.
6. The procedure for implementing current control procedures under this Chapter shall be defined by the Minister of Finance of
Georgia.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Article 257 – Time study
1. To determine the level of a taxpayer’s revenue, the volume of supplied goods/delivered services and the number of hired natural
persons, the tax authority may survey the taxpayer’s economic activity and conduct a time study of the taxpayer’s activity.
2. The time study shall be conducted by keeping uninterrupted records of the volume of goods manufactured and or
supplied/services delivered by the taxpayer. If necessary, an authorised person of the tax authority may install metering and other
technical devices and register their records at the end of each day when the time study is conducted.
3. A time study shall be conducted for at least seven days. The time of commencement and completion of a time study shall be
determined by a particular calendar date and/or by the date of completion of a procedure subject to control.
4. If so provided for by an agreement made by the tax authority and any other administrative authority, a representative of such
administrative authority may participate in and, if necessary, an expert/specialist be contracted for conducting the time study.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 2571 – Tax monitoring
1. By assigning the authorised person/persons for a term of up to 6 months to the place of economic activity of a taxpayer engaged
in economic activity, the tax authority may conduct tax monitoring and use the information obtained to determine the taxpayer’s
tax obligation at the moment of a tax audit. The period of tax monitoring may be prolonged in agreement with the Head of the
Revenue Service.
2. The goal of tax monitoring is to carry out an independent quantitative accounting of the acquisition, spending, and losses of the
main type of inventory holdings used by the taxpayer in his/her economic activity, as well as of the supply of finished products (by
types) by such taxpayer, and to obtain information on such accounting and/or identify possible risks of concealing/hiding a taxable
object or information related to it.
3. The procedure for conducting tax monitoring shall be determined by the Minister of Finance of Georgia.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
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Article 258 – Controlling purchase
1. The purpose of controlling purchase of goods/services shall be to determine the actual volume of revenue earned from the
supply of goods/delivery of services and/or reveal a violation of the legislation of Georgia.
2. The tax authority may make a controlling purchase of goods/services from a taxpayer, and/or determine the price of
goods/services by offering to make a controlling purchase from a taxpayer, and/or offer goods/services to be purchased to a
taxpayer, to reveal a violation of the tax legislation of Georgia.
3. In making a controlling purchase and/or offering a controlling purchase, the authorised person of the tax authority may act as a
mystery consumer. For this purpose, the head of the tax authority may issue false documents to the person implementing current
control.
4. In making a controlling purchase of goods/services from and/or offering a controlling purchase of goods/services to the taxpayer,
the tax authority may use technical devices for recording the procedure without a judge’s order.
5. If the goods acquired through a controlling purchase do not leave the premises of the trade outlet and their appearance and
packaging have not been damaged, then the transaction shall be subject to cancellation based on the controlling purchase record
(the goods purchased shall be returned to the seller and the money – to the buyer).
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Article 259 – Control over observance of rules for using cash registers
1. An authorised person of the tax inspection may, without a court decision, in accordance with procedures established by the
Minister of Finance of Georgia, exercise control over the observance of rules for using cash registers.
2. When a person engaged in economic activity accepts payment in cash from a customer during the supply of goods/delivery of
services, the relevant data shall be recorded by using a cash register. A customer shall be a person who makes a cash payment for
any goods supplied (to be supplied)/services delivered (to be delivered) to him/her.
3. The rules for maintaining the State Register of Cash Registers, for operating cash registers, registering cash registers with the tax
authority, sealing petrol filling station flow meter pumps, and issuing a document equated with a receipt, as well as details to be
recorded on a cash register receipt, shall be determined by the Minister of Finance of Georgia.
4. The following persons shall be released from the obligation to use cash registers:
a) a person, when accepting payment from a customer, for which:
a.a) a strictly controlled accounting document approved under the legislation of Georgia evidencing the fact of payment in cash is
used;
a.b) a tax invoice is made out for supply of goods/delivery of services;
b) a natural person, who does not employ hired labour and sells agricultural produce or goods produced (processed) from
agricultural produce on his/her personal or family farm, regarding this part of his/her activity;
c) a natural person holding the status of a micro business, except for natural persons holding the status of a micro business engaged
in a certain activity or engaged in an activity within the administrative boundaries of a certain municipality; defined by the
Government of Georgia;
c1) a person holding the status of a fixed tax payer – regarding the part of such a person’s activity that is subject to a fixed tax
(except for the activity taxable at the rate provided for under Article 953(1)(b) of this Code);
d) a natural person engaged in economic activity who has no obligation to be registered as an entrepreneur natural person;
e) a person supplying goods/delivering services and accepting cash in the customer’s territory (houses, organisations, enterprises) –
regarding this part of such a person’s activity, on the condition of issuing a document equated with a receipt;
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e1) a person – in the cases provided for by the Minister of Finance of Georgia. In such cases, the person shall be authorised to issue
a document equated with a receipt, regarding this part of such a person’s activity;
f) a person supplying goods/delivering services and accepting cash by means of automated or mechanical devices – regarding this
part of such a person’s activity;
g) an entrepreneur natural person performing a retail sale as a street vendor, as well as a person selling newspapers and magazines
– regarding this part of such person’s activity;
h) a person – regarding the part of such a person’s activity defined by Article 99(d) of this Code;
i) a banking institution, or a microfinance organisation;
i1) a payment service provider and its agent referred to in the Law of Georgia on Payment System and Payment Service –
regarding activity provided for by the Law of Georgia on Payment System and Payment Service;
j) persons setting up a gambling club, a slot machine club, or a betting house – with regard to this activity, except for the activity
carried out with regard to the organisation of slot machine games in a systemic and electronic form and the organisation of betting
house games in a systemic and electronic form.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6053 of 24 April 2012 – website, 27.4.2012
Law of Georgia No 6312 of 25 May 2012 – website, 12.6.2012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 2590 of 9 February 2023 – website, 24.02.2023
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 260 – Visual inspection
1. To exercise tax control, an authorised person of the tax authority may visually inspect the premises, buildings, fixed assets and
inventory holdings of a person.
2. The dwelling of a natural person can be inspected only based on a court decision.
3. Checking a taxpayer's documents during a visual inspection shall be prohibited.
4. Visual inspection procedure does not involve the visual inspection or checking of the contents of safes, cabinets, drawers and
other similar pieces of furniture and receptacles.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 261 – Taking inventory
1. The head of the tax authority may, without a court decision, issue an order for taking stock of inventory holdings and/or fixed
assets of a person holding excisable goods (the head of the tax authority may issue an order for taking stock of inventory holdings
and/or fixed assets of a person holding non-excisable goods for a maximum of two times in a calendar year, and an inventory may
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be checked for a third time by an order of the Head/Deputy Head of the Revenue Service). To have an inventory checked within a
reasonable time, the taxpayer's manager (director) shall set up an Inventory Commission within two working days after being
served with such an order. The Inventory Commission shall comprise the persons who are well familiar with goods subject to
inventory, their price and their original records and, if so requested by the tax authority, also employees of and/or specialists
contracted by the tax authority. The Inventory Commission shall be obliged, in full and on time, to take stock of inventory
holdings and/or fixed assets at the place of their production and storage, compare the obtained inventory with the respective
accounting data, and record the results in the Inventory Report of Inventory Holdings and/or Fixed Assets.
2. The head of the tax authority may himself/herself set up an Inventory Commission by an order on taking an inventory, and
determine its composition and, if necessary, inter alia, if the taxpayer's manager (director) does not issue an order setting up an
Inventory Commission within the time fixed in the first paragraph of this article, issue an order setting up such an Inventory
Commission. When determining the composition of the Inventory Commission in accordance with this paragraph, including the
taxpayer’s representative(s) in the commission shall be provided for.
3. The head of the tax authority may, without a court decision, issue an order on random sampling inventory of specific types of
inventory holdings and/or fixed assets. The tax authority may take stock of the actual condition inventory of the inventory
holdings and/or fixed assets without setting up an Inventory Commission, in the presence of the taxpayer or his/her representative.
The taxpayer shall produce, within two working days, the accounting records of the balances of inventory holdings and/or fixed
assets, after which an authorised person of the tax authority shall compare the data of the actual records and the accounting
records for inventory holdings and/or fixed assets, recording all of them in the Inventory Report of Inventory Holdings and/or
Fixed Assets.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Chapter XXXVIII – Tax Audit
Article 262 – Types of tax audit
A tax audit may be a correspondence audit or a field audit.
Article 263 – Correspondence tax audit
1. A correspondence tax audit shall be conducted by an order of an authorised person of the tax authority, for auditing specific
matters defined by the order.
2. During a correspondence tax audit, the tax authority may request, according to the procedure provided for by this Code, that
accounting documents and/or taxation-related information be presented.
3. A correspondence tax audit shall be conducted without visiting the person’s place of activity, based on the person’s taxation-
related information available at the tax authority, as well as on clarifications and accounting documents provided by the taxpayer.
4. If any mistakes revealed as a result of a correspondence tax audit entail a change in the amount of tax payable, the authorised
person conducting the correspondence tax audit shall draw up a tax audit report.
Article 264 – Field tax audit
1. A field tax audit shall be conducted based on an order of an authorised person of the tax authority.
2. The taxpayer shall be sent a written or electronic notice of a field tax audit at least 10 working days prior to the commencement
of the audit.
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3. The audit shall commence no later than 30 days after serving the notice upon the taxpayer. If the audit cannot be started within
that time, the notice shall be invalid.
4. A field tax audit may fully or partially audit the taxpayer’s activity.
5. A field tax audit may also include the procedures of current control over the taxpayer’s activity.
6. A field tax audit may not continue for more than three months. If necessary, the audit period may be prolonged for a maximum
of two additional months, in agreement with the Head of the Revenue Service.
7. In the course of a field tax audit, the taxpayer shall provide auditors with the same working conditions that normally exist at the
taxpayer’s premises.
8. An authorised person of the tax authority may request duly certified copies of accounting documents related to any tax
obligation and/or of any taxation-related information and, if the taxpayer fails to fulfil such a request, seize the original copy of
such a document, that shall be returned to the taxpayer upon the completion of the field tax audit. A seizure report shall be
executed if a document is seized.
9. If a tax audit cannot be continued once it is begun due to Force-Majeure or any other circumstances, an authorised person of the
tax authority shall make a decision on suspending the tax audit. The tax audit shall be resumed upon elimination of Force-Majeure
or any other circumstance. The flow of the term of the tax audit shall be renewed from the day of resuming such an audit.
10. If the specifics of a tax audit require that the audit be conducted in several stages, an interim report shall be executed after
completion of each stage.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 265 – Urgent field tax audit
1. An urgent field tax audit shall be conducted without a written notice, with a court’s permission, if:
a) the last tax audit detected significant violations of tax obligations by the taxpayer;
b) there is reliable information raising doubts as to the origin of the person’s financial and material resources;
c) there is reliable information on the growth of property or any other taxable object that has not been documented;
d) the Tax Returns and other documents filed with the tax authority do not confirm the reality of the objects of taxation and taxes
calculated;
e) a Tax Return or documents necessary for calculating and/or paying taxes have not been filed;
f) the tax authority has information that a person plans to evade tax obligations by departing from Georgia, transferring assets to
another person, destroying, concealing, or adjusting documents evidencing tax offences or by taking other measures.
2. A tax authority shall, within 48 hours after commencing an urgent field tax audit, apply to a court and obtain permission to
perform a field tax audit. Furthermore, if the application to a court for performing an urgent field tax audit is based on a
precondition under paragraph 1(f) of this article (the tax authority has information that a person plans to evade tax obligations by
transferring assets to another person), the tax authority shall have the right to impose a tax lien/mortgage on a tax payer’s
property, in particular on the assets under the precondition specified, within the value of the same assets, irrespective of whether
the tax payer has tax liabilities or not. If the court refuses to grant permission to the tax authority to perform the urgent field tax
audit, the tax lien/mortgage shall be cancelled. In addition, the tax authority shall, after the urgent field tax audit is completed,
make the volume of the tax lien/mortgage applied appropriate to the assessed tax liabilities in proportion to (commensurate with)
the amount of the liabilities, specifying the asset/part of the asset to which the right to tax lien/mortgage applies.
3. Before obtaining court permission, the tax authority may not commence an urgent field tax audit. The representatives of the tax
authority may seal only those tax documents and inventory holdings of the taxpayer that are necessary for performing an urgent
field tax audit.
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4. If the court does not grant permission to perform an urgent field tax audit to the tax authority within the fixed time, the tax
authority shall be obliged to unseal the tax documents and/or inventory holdings of the taxpayer.
Decision No 2/8/734 of the Constitutional Court of Georgia of 28 December 2017 – website, 9.1.2018
Law of Georgia No 2640 of 27 June 2018 – website, 6.7.2018
Article 266 – (Deleted)
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 267 – Tax audit report
The findings of a tax audit shall be reflected in a report that shall indicate:
a) all the factual circumstances, evidence and arguments, which had substantial importance in determining the taxpayer’s tax
obligation. If the audit relied on an expert’s opinion, the report shall reflect the content of such an opinion.
b) the provision of the Tax Code of Georgia and/or of any act of the tax legislation of Georgia that guided the auditors in
determining the taxpayer’s tax obligation;
c) the exact dates that the taxpayer’s tax liabilities arose (if identifiable), tax and fine calculations, the total amount payable or
receivable, the details (if necessary – copies) of documents evidencing the origin of such claims and liabilities, as well as the
content of annexes to the tax audit report.
Article 268 – Making decisions based on a tax audit report
1. The tax authority shall make a decision on assessing or not assessing taxes and/or fines, based on the tax audit report; a copy of
such a decision shall be presented to the taxpayer along with the relevant Tax Notice.
2. If an administrative offence is revealed, the authorised person of the tax authority who is performing the tax audit shall execute
an administrative offence report.
3. If any signs of a crime are revealed as a result of a tax audit, the relevant materials shall be immediately forwarded to the
investigation authority of the competent jurisdiction.
4. To develop a uniform tax administration practice, by decision of the Minister of Finance of Georgia, a Board of Auditors shall be
set up, which shall comprise employees of the Ministry of Finance of Georgia and the Revenue Service, as well as contracted
specialists.
5. If making a decision on the findings of a tax audit introduces a principle/methodology different from existing
principles/methodologies of taxation and/or application of penalty for an offence, the tax authority may apply to the Board of
Auditors, who may within 20 days make a decision on applying or not applying such a principle/methodology. The decision of the
Board of Auditors shall be binding upon the tax authority.
SECTION XIII
TAX OFFENCE AND RESPONSIBILITY
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Chapter XXXIX – General Provisions
Article 269 – Tax offence and general principles of fiscal responsibility
1. A tax offence shall be a person’s unlawful act (action or omission of action), for which responsibility is provided for under this
Code. Responsibility for a tax offence may be imposed upon a person only on the grounds and according to the procedure provided
for by this Code.
2. When imposing a penalty for a tax offence, if the responsibility for such an act has been abolished or mitigated by the law, the
norm under the new law shall apply, whereas if the responsibility has been introduced or aggravated by the law, the norm being
in force at the time of committing the act shall apply.
21. If the responsibility for such an act has been abolished or mitigated before a tax dispute has been resolved, the authority
considering the dispute shall be obliged to apply the norm established by the new law.
3. The responsibility for committing any offence provided for by this Code shall be imposed upon an enterprise/organisation and a
natural person. Imposing a tax penalty on a person for a tax offence shall not release the person from the obligation to pay any
taxes payable.
4. Imposing a tax penalty on an enterprise/organisation for a tax offence, based on relevant grounds, shall not release its officials
from administrative, criminal or other types of responsibility, determined by the legislation of Georgia.
5. A person shall not be held responsible under this Section, if a tax offence is caused due to Force-Majeure. Force-Majeure shall
mean any emergency or extraordinary circumstances that render fulfilment of the obligations under this Code impossible and the
occurrence of which does not depend on a person’s will, including:
a) natural disaster (earthquake, flood, landslide, avalanche, fire, etc.)
b) restrictions on foreign trade, declaration of a state of emergency/martial law, as well as any other decision of a state authority
c) civil commotion, strike.
51. (Deleted – 1.5.2015, No 3581).
6. The fine provided for under this Section for misstatement in a tax return/tax calculation shall not be imposed upon a person
who has submitted an adjusted tax return/calculation to a tax authority before a court decision on performing a tax audit or a
relevant decision of the tax authority has been communicated, or a tax offence report has been drawn up.
61. (Deleted – 28.6.2019, No 4906).
7. The tax authority, the authority considering a dispute or the court may release a faithful taxpayer from a tax sanction under this
Code, if the tax offence was caused by the payer’s mistake/lack of knowledge.
71. (Deleted – 28.6.2019, No 4906).
8. For the purposes of this Section, an offence shall be deemed repeatedly committed, if the same act has been committed within
12 months after revealing the previous offence. At the same time, an offence provided for under Article 281 of this Code shall not
be deemed repeatedly committed, if a person committed offences provided for under the same article on the same day, on isolated
premises.
9. An authorised person of the tax authority may, without executing a Tax Offence Report, define to a person a term for
eliminating a tax offence, in the manner and in cases determined by the Minister of Finance of Georgia. Such a person shall not be
held responsible for the same tax offence during the time-frame of validity of such a term.
10. If the offence specified in Article 2884 is discovered, a natural person who has used the right to deduct non-taxable minimum
from gross income and the right to refund/deduct the relevant tax amount shall not be held liable under Article 275(2) of this
Code.
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11. Fifty per cent of the amounts of fines assessed as a result of a tax audit shall be cancelled if, within 30 days after the delivery of
a tax notice issued as a result of the tax audit, a taxpayer has fully paid to the budget the amount equivalent to 50% of taxes
provided for under the tax notice, and of the fines and the person has recognised, within the same period, the amount provided for
under the tax notice concerned.
Law of Georgia No 4705 of 20 May 2011 – website, 01.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3015 of 26 December 2014 – website, 30.12.2014
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 4065 of 17 July 2015 – website, 29.7.2015
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 270 – Tax sanction
1. A tax sanction shall be a measure of responsibility for a committed tax offence.
2. Tax sanctions shall apply in the form of a warning, penalty interest, monetary fine, seizure of offence goods and/or a transport
vehicle, in the cases provided for by this Code.
3. Different responsibilities or repeated responsibility may not be imposed on a person for one and the same tax offence.
4. If several tax offences have been revealed, a tax sanction shall apply for each offence severally. At the same time, a less serious
sanction shall not be subsumed into a more serious sanction.
5. (Deleted – 28.6.2019, No 4906).
6. Tax penalty interest shall not be accrued on a tax sanction.
7. A warning instead of a monetary penalty may be applied for committing tax offences provided for by Article 273 or 281, 286(1)
or (11), or Article 2885 or 291 of this Code (except when these offences have been committed repeatedly).
71. (Deleted – 28.12.2012, No 189).
8. (Deleted – 8.11.2011, No 5202).
Law of Georgia No 3880 of 7 December 2010 – LHG III, No 69, 15.12.2010, Art. 421
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 4470 of 22 March 2011 – website, 1.4.2011
Law of Georgia No 4705 of 20 May 2011 – website, 01.6.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 271 – Tax offence proceedings
1. A tax offence case shall be conducted by a tax authority. The procedure for conducting tax offence cases shall be established by
the Minister of Finance of Georgia.
11. (Deleted – 28.6.2019, No 4906).
2. Where a tax offence has been revealed, an authorised person of the tax authority shall draw up a tax offence report, except
where the tax offence has been indicated in the tax audit report.
21. In case an offence provided for in Articles 277-279 of this Code has been revealed, the National Bureau for Enforcements shall
draw up a tax offence report as well.
3. (Deleted – 28.6.2019, No 4906).
4. A person authorised to draw up a tax offence report shall consider a tax offence case at the scene of the offence, and administer a
tax sanction to such a person. In such a case, the relevant responsibility shall be imposed upon such a person based on the tax
offence report that shall be deemed to be a Tax Notice.
5. A tax offence report shall be presented to the person having committed the offence, who shall have the right to provide
clarifications and notes that shall be reflected in or appended to the report. A copy of a tax offence report shall be served upon or
sent to the offender.
6. If a tax offence report does not reflect any details defined by the legislation of Georgia, or a tax offence report is executed in
violation of the law, the head of the relevant authority or the authority considering the case shall release the person from tax
liability.
7. If elements of a crime are detected, the materials shall be immediately forwarded to the investigation authority of the
competent jurisdiction.
8. In the cases provided for by the seventh paragraph of this article, an authorised person of the tax authority shall issue an order
on the tax offence case within 30 days after the investigation authority or the court has delivered a relevant decision. An order
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imposing a tax sanction shall be deemed a Tax Notice. Any order issued in violation of the above time limit shall be void.
9. (Deleted – 20.5.2011, No 4705).
10. (Deleted – 28.6.2019, No 4906).
11. (Deleted – 28.6.2019, No 4906).
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4705 of 20 May 2011 – website, 01.6.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Chapter XL – Types of Tax Violations and Responsibility
Article 272 – Penalty interest
1. Penalty interest is a tax penalty imposed upon a person for failure to pay the payable tax amount within the time limit fixed by
the tax legislation.
11. If, during customs clearance of goods provided for in Article 5(4) of the Customs Code of Georgia, a failure to pay any payable
import duty or duties payable on temporary admission of goods before the fixed deadline has been revealed, a competent authority
of the Ministry of Internal Affairs of Georgia may impose a penalty interest, under the procedure established by a joint order of
the Minister of Finance of Georgia and the Minister of Internal Affairs of Georgia.
2. Penalty interest shall be assessed on the payable tax amount and shall be the difference between the taxpayer’s outstanding tax
liability and the sum of overpaid taxes. Unless otherwise provided for by this Code, the penalty interest shall be assessed for each
day of overdue payment, from the day following the day of the expiry of the due date.
21. Surcharge shall not be assessed any more from the date when 3 years pass after the day of origination of an obligation to assess
it.
3. From the entry into legal force of the ruling on recognising as admissible a person’s application for insolvency, and on opening
the rehabilitation or bankruptcy regime, or from the revocation of a licence for the respective activity of an insurer or of a licence
for the voluntary private pension activity, or from the commencement of the liquidation process by the National Bank of Georgia
of a banking institution, a microfinance organisation, a non-banking deposit institution – credit union, a payment service provider,
an asset management company, an investment fund of its sub-fund, a special purpose vehicle for securitisation or its division until
the end of the respective regime, the assessment of surcharge on overdue tax liabilities that existed before commencement/opening
of the said regime shall be ceased. In addition, if the rehabilitation plan is approved, during its validity period, no surcharge shall
be assessed on an overdue tax liability under the rehabilitation plan, except for a sum (sums) of a tax due for payment according to
the rehabilitation plan.
31. No surcharge shall be assessed, from the entry into legal force of the court ruling on commencing the bankruptcy regime, on
the tax liability having arisen after the commencement of the bankruptcy regime.
4. Penalty interest shall account for 0.05% of the outstanding tax liability for each overdue day of payment. If the tax payment is
overdue, the day when the tax is paid shall be deemed as an overdue day.
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5. (Deleted – 6.3.2024, No 4056).
6. In the cases provided for by Article 64(2)(a) of this Code, if a person has been served with a Tax Notice after the due day of tax
payment, penalty interest shall be assessed from the 30th day after the Tax Notice has been served.
7. No penalty shall be imposed on (except the taxes, in relation to which the person has a tax agent’s function):
a) the suppliers of goods/providers of services – with respect to the budget obligations arising due to non-payment by purchasing
organisations of the cost of goods supplied/services delivered based on allocations provided for under the Law of Georgia on the
State Budget of Georgia for the respective year and under the budgets of the municipalities – pro rata to the amount of actual
financing of their cost and their share in the total volume of goods supplied/services delivered;
b) legal entities under public law, implementing projects (including, preparatory phases of projects) defined under international
agreements ratified by the Parliament of Georgia, with which the Ministry of Finance of Georgia has signed a Project
Implementation Authorisation agreement – in respect to the tax liabilities originating from the scope of such projects. The list of
legal entities under public law implementing the above projects shall be approved by the Minister of Finance of Georgia.
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5169 of 28 October 2011 – website, 11.11.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Law of Georgia No 7169 of 18 September 2020 – website, 25.9.2020
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 3940 of 15 December 2023 – website, 27.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 4056 of 6 March 2024 – website, 14.3.2024
Article 273 – Violation of the procedure for registration as a taxpayer
Violation of the procedure determined by the legislation of Georgia for registration as a taxpayer, –
shall entail the imposition of a fine on the person in the amount of GEL 500.
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Article 274 – Violation of the time limit for filing Tax Return/tax calculations
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1. Violation of the time limit determined by the tax legislation of Georgia for filing a tax return/tax calculation with the tax
authority if the delay period does not exceed 2 months, –
shall entail the imposition of a fine in the amount of 5% of the sum of a tax to be assessed for payment on the basis of the tax
return/tax calculation for each overdue complete/incomplete month (incomplete months shall be counted as one month). At the
same time, the total amount of a penalty for the entire overdue period shall not exceed 30% of the sum of a tax to be assessed for
payment.
2. Violation of the time limit determined by the tax legislation of Georgia for filing a tax return/tax calculation with the tax
authority if the delay period exceeds 2 months, –
shall entail the imposition of a fine in the amount of 10% of the sum of a tax to be assessed for payment on the basis of the tax
return/tax calculation.
3. If the sum of a tax to be assessed for payment under a tax return/tax calculation equals zero, the fine under this article shall not
be imposed on a person.
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Article 275 – Understating taxes in a Tax Return/tax calculation
1. Understating payable taxes in a Tax Return/tax calculation by a person, if caused by tax control authority changing the moment
(period) of origin of the person’s tax liability –
shall entail the imposition of a fine on the person in the amount of 10% of the understated sum of payable taxes.
2. Understating payable taxes in a Tax Return/tax calculation, except in the cases provided for by paragraphs 1, 21 and 22 of this
article, –
shall entail the imposition of a fine in the amount of 50% of the understated sum of payable taxes.
21. Understatement of a tax in a Tax Return/tax calculation if the amount of the understated tax does not exceed 5 % of the tax
amount specified in the Tax Return/tax calculation, –
shall entail the imposition of a fine in the amount of 10 % of the understated tax amount.
22. Understatement of a tax in a Tax Return/tax calculation if the amount of the understated tax is more than 5 % and does not
exceed 20 % of the tax amount specified in the Tax Return/tax calculation, –
shall entail the imposition of a fine in the amount of 25 % of the understated tax amount.
3. Overstating a deductible/refundable amount in a Tax Return/tax calculation shall be considered as an understatement of the
payable tax amount in a tax return/tax calculation and it shall, in a respective case, entail the liability under paragraphs 1-22) of
this article.
4. Understating payable taxes in a Tax Return in excess of GEL 100 000 shall be deemed a tax evasion in large amounts and entail
responsibility under the procedure established by the criminal legislation of Georgia.
5. The total amount of the fines imposed under this article as a result of a tax audit must not exceed the sum of the tax amounts
assessed for payment a result of the tax audit.
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5649 of 27 December 2011 – website, 9.1.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
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Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Article 276 – Violation of gambling business rules
A person’s activity without a sign of gambling business fee payment or without a seal on the object of gambling business fee
payment, if such obligation is determined by law –
shall entail the imposition of a fine on the person in the amount of 100% of the gambling business fee payable on such an object of
gambling business fee.
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Article 277 – Resisting an authorised person of the tax authority
1. Resisting an authorised person of the tax authority or the National Bureau for Enforcement, ignoring a legal request of such a
person, that impedes implementation of a measure provided for by the tax legislation of Georgia –
shall entail the imposition of a fine on the person in the amount of GEL 800.
2. Repeatedly committing the act referred to in the first paragraph of this article
shall entail the imposition of a fine on the person in the amount of GEL 2 000.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Article 278 – Disposal of seized property and removal of the seal of the tax authority or of the National Bureau for Enforcement
Disposal of seized property, removal of the seal of the tax authority or of the National Bureau for Enforcement by a person without
agreement of the tax authority –
shall entail the imposition of a fine on the person in the amount of GEL 4 000.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Article 279 – Failure to present information to the tax authority
1. In case of a request of the tax authority in the manner provided for by this Code, failure to submit to the tax authority
accounting documents and/or taxation-related information, or failure to submit the list of assets within the time limit fixed by the
tax authority or the National Bureau for Enforcement, –
shall entail the imposition of a fine on the person in the amount of GEL 400.
2. Repeatedly committing the act referred to in the first paragraph of this article –
shall entail the imposition of a fine on the person in the amount of GEL 1 000 for each subsequent repeated act.
3. Submitting wrong information on writing off inventory holdings to a tax authority, –
shall carry a fine in the amount of the unconfirmed accounting value of the inventory holdings based on submitted information.
4. (Deleted – 28.6.2019, No 4906).
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5. (Deleted – 28.6.2019, No 4906).
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 2791 – Violation of the period for submitting statements or submission of incomplete reports by a multinational enterprise
Violation of the period set for submitting statements under Article 701 of this Code or submission of incomplete reports to a tax
authority, –
shall carry a fine in the amount of GEL 5 000.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 2792 – Failure of the Reporting Financial Institution to fulfil the commitment under the Agreements on Automatic
Exchange of Information
1. Violation by the Reporting Financial Institution of the period for submitting the information under the Agreements on
Automatic Exchange of Information to the tax authority, –
shall carry a fine for a person in the amount of GEL 3 000 for each delayed day. In addition, the total sum of the sanction
calculated for the whole period of delay must not exceed GEL 100 000.
2. Failure of the Reporting Financial Institution to comply with the request of the tax authority for submitting additional
information in order to verify the information under the Agreements on Automatic Exchange of Information, within the set
period of time, –
shall carry a fine for a person in the amount of GEL 10 000.
3. Repeated commission of the act provided for by paragraph 2 of this article, –
shall carry a fine for a person in the amount of GEL 20 000 for each subsequent commission.
4. Incomplete/incorrect submission by the Reporting Financial Institution of the information under the Agreements on Automatic
Exchange of Information to the tax authority, –
shall carry a fine for a person in the amount of GEL 10 000 for each reportable account missing in the information submitted, or
incompletely/incorrectly submitted. In addition, the total amount of the fine imposed under this paragraph must not exceed GEL
100 000 for each reporting period.
5. The fine provided for by paragraphs 1–4 of this article shall not be imposed on a person if he/she can prove that the offence in
question has been caused by a reason beyond his/her control, including if it becomes known that the person has no obligation to
submit the information under the Agreements on Automatic Exchange of Information.
Law of Georgia No 2138 of 30 November 2022 – website, 15.12.2022
Article 280 – Illegal tax deduction
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1. Obtaining a deduction as a result of a non-commodity transaction or a fictitious transaction, or a deduction based on a fake VAT
deduction document –
shall entail the imposition of a fine on the person in the amount of 200% of the deducted tax amount.
2. The Minister of Finance of Georgia shall define the cases and circumstances, when a transaction can be regarded as non-
commodity and/or fictitious.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Article 281 – Violation of rules for using cash registers
1. Working without a cash register when accepting cash payments from customers, –
shall entail the imposition of a fine on a taxpayer (except for a natural person renting a mobile trading place located within the
market territory) in the amount of GEL 200.
2. (Deleted – 08.11.2011, No 5202).
3. Failure to use a cash register when accepting cash payments from customers -
shall entail the imposition of a fine on the taxpayer in the amount of GEL 200.
4. (Deleted – 20.5.2011, No 4705).
5. Showing in a receipt an amount less than what has actually been paid –
shall entail the imposition of a fine on the taxpayer in the amount of GEL 200.
6. (Deleted – 20.5.2011, No 4705).
7. Loss of a cash register (other than GPRS and CRYPTO fiscal cash registers) by a taxpayer, unless established that such loss has
been caused by the unlawful act of any other person, –
shall entail the imposition of a fine on the taxpayer in the amount of GEL 3 000.
8. Repeatedly committing the act defined by the seventh paragraph of this article within 60 days after revealing of the tax offence
–
shall entail the imposition of a fine on the taxpayer in the amount of GEL 6 000.
81. (Deleted – 22.6.2012, No 6547).
9. Operating in a petrol and/or gas filling station a flow meter without a seal or with a damaged seal of the tax authority shall entail
the imposition of a fine on the taxpayer in the amount of GEL 1 500.
10. Repeatedly committing the act defined by the ninth paragraph of this article – shall entail the imposition of a fine on the
taxpayer in the amount of GEL 15 000 for each subsequent repeated act.
11. The Government of Georgia may define different amounts of fines for tax offences committed within the administrative
boundaries of a municipality, but not less than 5% of the fines determined by paragraphs (1-10) of this article.
Law of Georgia No 4705 of 20 May 2011 – website, 01.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
http://www.matsne.gov.ge 20000000005001016012
Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 6942 of 15 July 2020 – website, 28.7.2020
Article 282 – Violation of VAT requirements
1. Conducting activities without registration as a VAT taxpayer –
shall entail the imposition of a fine on the person of 5% of the amount of VAT taxable transactions (except VAT exempt
transactions) carried out during the period of activity without registration.
2. Failure of a supplier of goods/provider of services to issue a tax invoice to the buyer, at the request of the latter –
shall entail the imposition of a fine on the person of 100% of the VAT amount of the taxable transaction.
3. Issuing of a tax invoice for a fictitious /non-commodity transaction or a fake tax invoice by a person –
shall entail the imposition of a fine on the person having made out/issued the tax invoice of 200% of the VAT amount indicated in
the tax invoice.
4. If the fine defined by paragraph 1 of this article is applied, the fines provided for by Articles 274 and 275 of this Code shall not
apply to the accounting period (periods) of conducting activities without registration as a VAT taxpayer, in relation to the VAT
declaration.
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 283 – Non-fulfilment of an obligation by a banking institution
1. If there is money in a person’s bank account, failure of a banking institution to fulfil the person’s Payment Order or the tax
authority’s Collection Order for transfer of tax to the state budget within due time, except as provided for by paragraph 2 of this
article, –
shall carry a fine in the amount of 0.15% for each day of delay of the part of funds in the account, which was to be fulfilled
completely or partially under the Collection/Payment Order.
2. The act defined in the first paragraph of this article, if accompanied by a transfer of funds in any other direction, not taking into
consideration Article 54(11)and Article 71(1)(e) of this Code -
shall entail the imposition of a fine of 10% of the amount transferred in such other direction but not less than GEL 500 and not in
excess of the amount indicated in the collection/payment order.
3. Opening by a banking institution of an account for a taxpayer without the taxpayer submitting documents evidencing that the
tax authority has assigned an identification number to the taxpayer (except for a foreign enterprise and natural person not engaged
in economic activity) or opening any other account for such a person in the presence of the decision of the tax authority on
imposition of seizure upon or on presentation of a collection order against the account of the taxpayer, –
shall carry a fine in the amount of 10% of the sum of payment transactions made from the accounts of the taxpayer but not less
than GEL 500.
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4. Failure of a banking institution to submit to the tax authority the information on opening of bank accounts for a taxpayer for
the first time, or on closing the last account of a taxpayer, in accordance with the requirements of Article 71(1)(a),(b),(c), and (f) of
this Code within the time limit fixed by the tax legislation of Georgia (in case of a contract with the Revenue Service – on the
conditions and within the time defined by the contract), if this is not caused by providing wrong information by such persons to
the banking institution and other organisations performing certain types of bank operations, –
shall carry a fine in the amount of GEL 300 for each account.
41. Failure of a banking institution to fulfil the obligation under Article 71(1)(c1) of this Code, –
shall carry a fine in the amount of GEL 300 for each account.
5. Performing a payment transaction before or within two working days after submitting the information on the accounts
provided for in the fourth paragraph of this article –
shall entail the imposition of a fine in the amount of 10% of the sum of the payment transaction but not less than GEL 500.
6. If the Revenue Service and a banking institution have signed a contract on electronic exchange of information (including
collection orders), the penalty provided for under the fifth paragraph of this article shall apply only for the violation of the time
limit defined by such contract.
7. Failure of a banking institution to fulfil the decision of the tax authority on seizure of a taxpayer’s account, –
shall carry a fine in the amount of 20% of the sum that has been transferred to another person by the taxpayer’s order but not
more than the amount of the liability.
8. If there is money in a person’s account, failure of the banking institution to fulfil the person’s Payment Order or the tax
authority’s Collection Order for writing off an amount or transferring tax to the budget in due time, if the taxpayer applies to the
tax authority in writing, shall result in the tax authority to impose the penalty interest that has been assessed on the taxpayer as a
result of such act of the banking institution, on that banking institution in the same amount. In this case no penalty shall be
imposed on the person.
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4963 of 24 June 2011 – website, 30.06.2011
Law of Georgia No 6211 of 15 May 2012 – website, 29.05.2012
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Article 284 – (Deleted)
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 285 – (Deleted)
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Article 286 – Transportation, sale, and non-accounting of goods without documents
1. Transporting goods for entrepreneurial activity without a waybill, the failure to issue a waybill at the request of the buyer or
refusing to accept a waybill when purchasing goods, –
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shall carry a fine in the amount of GEL 500.
11. Transporting round timber (logs), tree-plants or products of their primary processing for entrepreneurial activity without a
waybill, the failure to issue a waybill at the request of the buyer or refusing to accept a waybill when purchasing goods, if the
market value of the round timber (logs), tree-plants or products of their primary processing transported or delivered/to be
delivered without a waybill does not exceed GEL 1 000 –
shall carry a fine for a person in the amount of GEL 500 and seizure of the goods.
12. Transporting round timber (logs), tree-plants or products of their primary processing for entrepreneurial activity without a
waybill, the failure to issue a waybill at the request of the buyer or refusing to accept a waybill when purchasing goods, if the
market value of the round timber (logs), tree-plants or products of their primary processing transported or delivered/to be
delivered without a waybill exceeds GEL 1 000 but does not exceed GEL 10 000 –
shall carry a fine for a person in the amount of GEL 5 000 and seizure of the goods.
13. Transportation of a pharmaceutical product subject to the reference price for entrepreneurial activity without a waybill, or
failure to issue a waybill at the request of a buyer or refusal to accept a waybill when purchasing goods, –
shall carry a fine for a person in the amount of GEL 1 000.
14. Repeated commission of an act provided for by 13 of this article, –
shall carry a fine for a person in the amount of GEL 15 000.
15. Commission of an act provided for by 13 of this article for a third time and each subsequent commission thereafter, –
shall carry a fine for a person in the amount of GEL 30 000.
2. Repeatedly committing the act provided for in paragraph 1 of this article repeatedly, -
shall carry a fine for a person in the amount of GEL 5 000.
3. (Deleted – 28.12.2012, No 189).
31. (Deleted – 14.7.2020, No 6817).
32. An act under paragraph 11 or 12 of this article if the market value of the goods transported or delivered/to be delivered
without a waybill exceeds GEL 10 000, –
shall entail the imposition of a fine on a person in the amount of Gel 10 000 and seizing the goods.
4. Revealing inventory holdings of a taxpayer that are not recorded in accounting documents, and not accompanied by the original
payment documents -
shall entail the imposition of a fine on the person in the amount of 50% of the market value of such inventory holdings at the
moment of revealing.
5. In the cases provided for by paragraphs (1-4) of this article, the penalty shall apply if the waybill does not indicate or incorrectly
indicates (except the cases, where there is a technical error that cannot have any significant impact on the result):
a) date and number of execution of the document;
b) name, identification number or name, surname and personal number of the party to the economic transaction;
c) name and/or quantity of goods;
d) where a pharmaceutical product subject to the reference price is involved – also the registration number of the pharmaceutical
http://www.matsne.gov.ge 20000000005001016012
product, the unit price of the pharmaceutical product and/or the factual address of a party to the business transaction;
e) the name, date and number of a respective document certifying the origin, purchase or import of round timber (logs) or tree-
plants or their product of primary processing;
f) the special tag number of round timber (logs) or tree-plants or their product of primary processing (except for cases defined by
the Minister of Finance of Georgia when indication of a special tag number is not mandatory).
6. The responsibility determined by the first paragraph of this article shall not be imposed on a person in the case:
a) of transportation or delivery of primary (before industrial processing – before changing the commodity code) agricultural
produce, as well as regular or uninterrupted transportation or delivery of goods (electric or thermal energy, natural gas, water);
b) of transportation of goods accompanied by the appropriate documents related to crossing the customs border of Georgia;
c) of existence of a special VAT invoice;
d) in the case of distributing free of charge for advertising purposes, including through a retail seller, of goods that have no
independent consumer specifications and are an integral part of the delivery of the main goods/service;
e) of transportation of newspapers, magazines and the goods supplemented by their publishers in the same pack, except for the
original delivery by the publisher;
f) of transportation of the relevant goods in the state of emergency and with the aim of rendering emergency assistance (fire
service, rescue service, emergency medical aid, or energy supply or sewage system breakdown emergency response);
g) if no waybill has been issued in the given case, according to the order of the Minister of Finance of Georgia.
7. The penalty provided for under paragraphs 1, 2, 31 and 4 of this article shall not be imposed on a person having the status of a
micro business, or on a person with a fixed taxpayer status (except for the activity to be taxed with a rate provided for in Article 953
(1)(b) of this Code) within the scope of the activities subject to a special tax treatment.
8. For the purposes of this article:
a) money and bank plastic cards are not goods;
b) it is not mandatory to make out a waybill for the transportation of precious metals and stones, and of numismatic valuables if
they are transported by the National Bank of Georgia or a banking institution, and by an authorised legal entity under public law,
in a specially protected or controlled transport vehicle;
c) a pharmaceutical product subject to the reference price shall be a pharmaceutical product defined as such under the Law of
Georgia on Medicines and Pharmaceutical Activities.
9. Revealing at a taxpayer of any shortfall as provided for by this Code shall be deemed as supplying at market price at the moment
of revealing. Furthermore, if the inventory holdings shortfall was revealed as a result of inventory taken by a tax authority, a
person shall be additionally fined in the amount of 10% of the market value of the inventory holdings.
10. The penalties provided for in paragraphs 4 and 9 of this article shall not apply if:
a) the amount of the inventory holdings surplus and/or shortfall not reflected in the accounting records does not exceed 2% of the
similar type of recorded inventory holdings;
b) the taxpayer has reflected the information on the surplus and/or shortfall in tax reports and/or has provided such information to
the tax authority before commencement of inventory taking or tax audit, and according to this information, the surplus is
recognised as profit and the shortfall – as supply.
11. Revealing the offence provided for in paragraph 4 of this article, if the market value of the inventory holdings does not exceed
GEL 1 000 –
shall entail the imposition of a fine on the person in the amount of GEL 200.
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12. Repeatedly committing the act referred to in paragraph 11 of this article-
shall entail the imposition of a fine on the person in the amount of GEL 400 for each subsequent reoccurrence.
13. To identify and prevent the offences under paragraphs 1-13 of this article, an authorised employee of a tax authority may stop
a person and a vehicle, ask the person to produce his/her identity document, the documents accompanying the vehicle and the
goods, visually inspect the vehicle, also count the goods to establish conformity with the accompanying documents and use
technical equipment for recording these procedures. If the person or the driver of the vehicle does not comply, the authorised
employee of the tax authority may apply measures provided for by the legislation of Georgia.
14. In the cases provided for by paragraphs (1)-(3) of this article, the tax authority may seize goods without a court decision. The
procedure and terms of seizure provided or under this article shall be determined by an order of the Minister of Finance of
Georgia.
15. (Deleted – 12.12.2014, No 2946).
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1583 of 20 November 2013 – website, 3.12.2013
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 2275 of 1 December 2022 – website, 13.12.2022
Law of Georgia No 2626 of 22 February 2023 – website, 10.3.2023
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 287 – (Deleted)
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
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Article 288 – Violation of the rules for conducting micro or small businesses
Any act that, based on a ground under Article 85(4) or Article 89(2)(c) or (d) of this Code, has caused a tax authority to cancel the
status of a micro business or the status of a small business for a person, –
shall entail the imposition of a fine on the person in the amount of GEL 500.
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Article 2881 – Violation of business rules by a Special Trading Company
1. Exceeding by a Special Trading Company the income provided for in Article 241(4)(d.c) of this Code above the limit set by the
same subparagraph –
shall entail the imposition of a fine in the amount of 10% of the amount exceeded.
2. The purchase by a Special Trading Company of Georgian goods for subsequent delivery -
shall entail the imposition of a fine of 50% of the market value of the purchased goods.
3. Delivery of services by a Special Trading Company to a Georgian enterprise and/or a permanent establishment of a foreign
enterprise in Georgia –
shall entail the imposition of a fine of 50% of the amount received and/or to be received for delivering such services.
4. Delivery by a Special Trading Company of any fixed asset used in economic activity for up to 2 years –
shall entail the imposition of a fine of 50% of the amount received/to be received for delivery of such goods.
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Article 2882 – Violation of the procedure set for a fixed taxable activity
1. Performing activity by a person having the status of a fixed taxpayer during the period of suspension of such an activity, –
shall entail the imposition of a fine on the person in the amount of GEL 200.
2. Adding a taxable object of a fixed taxable activity by a person having the status of a fixed taxpayer without notifying the tax
authority –
shall entail the imposition of a fine on the person in the amount of GEL 200.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Article 2883 – Supply and transportation of non-excisable goods subject to mandatory marking without marking
Supply and transportation of non-excisable goods subject to mandatory marking without marking, –
shall entail the imposition of a fine on the manufacturer in the amount of the market value of the non-excisable goods subject to
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mandatory marking that were found without marking but not less than GEL 500.
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2884 – Non-submission, late submission and/or incorrect submission of information on the amounts paid and taxes
withheld according to the accounting month
1. Refund of excess amount by an employee within the scope of a non-taxable minimum and/or deduction of excess amount
against the tax liabilities, which is caused by non-submission, late submission and/or incorrect submission to a tax authority of
information on the amounts paid and the taxes withheld according to the accounting month, shall result in the imposition of a fine
on a person who was responsible for submitting the information. The fine shall be double the amount of the amount excessively
refunded and/or excessively deducted against the tax liabilities.
2. The fine specified in this article shall not be applied if the information on the amounts paid and the taxes withheld according to
the accounting month was submitted before the tax authority adopted a decision on refunding the non-taxable minimum.
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3015 of 26 December 2014 – website, 30.12.2014
Article 2885 – Failure to submit information about hired employees to the Register of Hired Employees
Failure of a person to submit information about hired employees to the Register of Hired Employees, –
shall carry a fine for the person in the amount of GEL 200 per each hired employee.
Law of Georgia No 2768 of 5 April 2023 – website, 18.4.2023
Article 289 – (Deleted)
Law of Georgia No 3880 of 7 December 2010 – LHG III, No 69, 15.12.2010, Art. 421
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 4065 of 17 July 2015 – website, 29.7.2015
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Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 290 – (Deleted)
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Article 2901 – (Deleted)
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 2902 – (Deleted)
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 291 – Other fines
Failure of a person to fulfil any obligation provided for under this Code, for which responsibility is provided for, but the amount of
fine is not defined by the this Code –
shall entail the imposition of a fine in the amount of GEL 100.
Chapter XLI – Tax Agreement
Article 292 – Essence of a tax agreement
1. A tax agreement may be concluded between the Revenue Service and a taxpayer to reduce the taxpayer’s:
a) tax arrears/a part of tax arrears;
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b) sum of a duty and/or the related penalty and surcharge which is administered by a tax authority.
2. This article shall not apply to current payments charged under Articles 155 and 205 of this Code.
3. In the case under paragraph 1(b) of this article Articles 293-295 of this Code shall apply accordingly.
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 3407 of 20 March 2015 – website, 26.3.2015
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Article 293 – Signing a tax agreement
1. The taxpayer shall submit an application for a tax agreement to the Revenue Service that may:
a) refuse to sign a tax agreement with the taxpayer;
b) submit the application, along with appended documents, to the Minister of Finance of Georgia for consideration at the
Government Meeting.
2. The Government of Georgia shall make a decision on signing a tax agreement, defining the amount payable and the time limit of
payment under the tax agreement.
3. The taxpayer shall be obliged to discharge the liabilities under the tax agreement within the term fixed by the agreement.
4. After the tax agreement has been signed, the head of the Revenue Service may make a decision on cancelling/not applying, in
whole or in part, the overdue tax liability compliance security measures.
5. After the terms and conditions of the tax agreement have been satisfied, the taxpayer’s overdue tax liability shall be reduced by
an individual administrative-legal act of the head of the Revenue Service.
6. If the liabilities under the tax agreement have not been satisfied within the fixed term, the tax agreement shall be deemed
cancelled, and fine in the amount of 10% of the unpaid sum shall be imposed on the taxpayer.
7. After the tax agreement has been signed, it shall be impermissible to reduce the amount assessed in the tax return for the
respective tax period by filing an adjusted Tax Return.
8. After a tax agreement on reducing the amount (overdue tax liability) additionally assessed, as a result of tax control, has been
signed:
a) a controlling/law-enforcement authority may not re-audit an audited period or matter and/or impose a tax/a sanction on a
taxpayer, except for the tax period or matter related to the person who merged with the taxpayer after concluding the tax
agreement with him/her;
b) a taxpayer may not initiate or resume a dispute on the grounds of any newly discovered/newly detected
circumstances/evidence.
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9. If a tax agreement is cancelled, the rights and obligations of the tax authority and the taxpayer arising under the agreement shall
be cancelled.
10. The procedure for signing a tax agreement shall be defined by an ordinance of the Government of Georgia.
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 6212 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Article 294 – Tax agreement form
1. The tax agreement shall be executed between the Revenue Service and a taxpayer.
2. The tax agreement shall indicate:
a) the taxpayer's name, identification number or name and surname, personal number, as well as other details (if necessary);
b) the content and terms and conditions of the agreement;
c) the time limit and procedure for appealing a tax agreement.
Article 295 – Appealing a tax agreement
A taxpayer may appeal a tax agreement if the tax agreement has been signed by an authorised person.
SECTION XIV
TAX DISPUTE
Chapter XLII – Tax Dispute Proceedings
Article 296 – General Provisions
1. A tax dispute may be resolved within the system of the Ministry of Finance of Georgia and in court.
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2. This Section sets forth the procedure for resolving a tax dispute within the system of the Ministry of Finance of Georgia.
3. An appellant may apply to the court at any stage of a tax dispute within the system of the Ministry of Finance of Georgia.
4. The procedure for tax dispute court proceedings shall be provided for by the legislation on administrative proceedings of
Georgia.
Article 297 – Authorities with competence for tax dispute resolution
1. The authorities having the competence to resolve a tax dispute within the system of the Ministry of Finance of Georgia shall be
the Revenue Service and the Dispute Resolution Council under the Ministry of Finance of Georgia (the dispute resolution bodies).
2. The Dispute Resolution Council shall be a tax dispute resolution body under the Ministry of Finance of Georgia.
3. A tax dispute within the system of the Ministry of Finance of Georgia shall include two stages, and it shall start with filing a
complaint with the Revenue Service, except as provided for in paragraph 31 of this article.
31. An advance ruling under Article 47(1) of this Code shall not be appealed in the Revenue Service. A person may appeal against
the advance ruling under Article 47(1) of this Code in the Dispute Resolution Council under the Ministry of Finance of Georgia.
4. The composition of the Dispute Resolution Council shall be defined by the Government of Georgia.
5. The dispute resolution bodies shall have regulations approved by the Government of Georgia that defines the procedure for
resolving an appeal and communicating with appellants.
6. The staff of the Dispute Resolution Council shall prepare appeals lodged with the Council for review; provide information on
legal proceedings to appellants and process decisions delivered by the Council.
7. The staff of the Dispute Resolution Council, by the decision of the head of staff, may hold a preparatory meeting to ascertain the
circumstances related to an appeal.
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Article 298 – Tax dispute settlement principles
1. A dispute resolution body, in resolving a dispute, shall be guided by the principles of fairness, objectivity, equality of arms and
impartiality.
2. The appellant’s tax obligations, within the system of the Ministry of Finance of Georgia may not be aggravated, as a result of a
tax dispute, except where an audit is conducted within the scope of such a dispute by consent of the taxpayer.
Article 299 – Initiating a tax dispute
1. A decision made by the tax authority with relation to a person, based on this Code, may be appealed to a dispute resolution body
in the manner provided for by this Chapter.
2. A tax audit report and the decision based on it shall be appealed along with the Tax Notice based on such documents. A tax
offence report/order shall be appealed in the manner provided for by this Chapter.
3. (Deleted – 13.5.2016, No 5092).
31. A decision of the Revenue Service on a taxpayer’s appeal related to the offences provided for under Articles 273 and 281 of this
Code shall be appealed to a court.
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4. A person may appeal a decision of the tax authority within 30 days after it has been served.
5. A person may deem the violation by the tax authority and/or a dispute resolution body of the time limit fixed for making a
decision as a dismissal of his/her application and appeal it in the manner provided for by this Chapter. The time limit for appealing
a decision issued in violation of the time limit shall commence from serving such a decision upon the person.
6. After 30-days, a dispute may be initiated on the grounds of newly discovered or newly revealed circumstances or evidence.
7. Newly discovered or newly revealed shall mean circumstances or evidence that the appellant did not know and could not have
known prior to delivery of a decision unfavourable for him/her and the timely presenting of which would have resulted in the
delivery of a decision favourable for the appellant.
8. A dispute may also be initiated if it is established that the appealed decision has not been sent to the appellant. In such a case,
the term of appeal shall commence from the day the appealed decision became known to the appellant.
9. An appeal shall be filed with a dispute resolution body usually in an electronic form. The form of the appeal shall be defined
under the regulations approved by the Government of Georgia.
10. The decision of the tax authority may be appealed even after the time limit for appeal has elapsed if the appellant proves that
failure to observe the time limit for appeal was caused by the circumstance beyond his/her control.
11. Appealing a decision of the tax authority shall not suspend the decision.
Law of Georgia No 4705 of 20 May 2011 – website, 1.6.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 649 of 21 April 2017 – website, 10.5.2017
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 300 – Filing an appeal for processing
1. A dispute resolution body shall not accept an appeal for processing if the appeal fails to meet the following procedural
requirements:
a) the appellant’s identification/personal number is not indicated in the appeal;
b) the appellant’s contact details are not indicated in the appeal;
c) the appeal fails to clarify the essence of claim;
d) a copy of an appealed decision or of a document related to its issuance (if any) is not attached;
e) pages of the appeal or of the documents attached thereto are not numbered;
f) the appeal or the documentation attached thereto are illegible;
g) the appeal or a document attached thereto is not drawn up in the state language of Georgia;
h) the appeal is not signed;
i) the appeal has been filed by the representative and the document confirming the power of representation is not attached
thereto.
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2. If the appeal does not meet the procedural requirements, the appellant shall be given written notice, as well as at least five days
to remedy the shortcomings in the appeal. The dispute resolution body may prolong the time for remedy of the shortcomings in
the case of a well-grounded request of the appellant.
3. A dispute resolution body may accept an appeal for processing irrespective of a shortcoming, if such a shortcoming does not
essentially impede the resolution of the appeal.
Law of Georgia No 649 of 21 April 2017 – website, 10.5.2017
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 301 – Refusal to resolve an appeal
The dispute resolution body shall not resolve an appeal if:
a) the appellant refuses to continue the dispute;
b) the subject of the claim falls beyond the scope of authority of the dispute resolution body;
c) the appeal has been lodged by an unauthorised person;
d) there is no subject matter of the dispute;
e) the time limit for lodging the appeal has elapsed;
f) the appeal does not meet the procedural requirements and the appellant has failed to remedy the shortcoming within the time
limit fixed by the dispute resolution body;
g) there is a decision made by the same body on the same subject of the dispute with relation to the same appellant;
h) (Deleted – 14.7.2020, No 6817);
i) the appellant has applied to the court with respect to the same subject of the dispute;
j) the appellant has passed away;
k) the appealed Tax Notice reflects an acknowledged overdue tax liability. The appeal shall not be resolved with respect to the
acknowledged overdue tax liability;
l) the appellant cannot be found;
m) the appeal is anonymous;
n) a tax agreement has been signed with respect to the appealed overdue tax liability.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 302 – Resolving an appeal
1. A dispute resolution body shall resolve an appeal within 20 days.
2. A dispute resolution body shall resolve an appeal only to the extent of the appellant’s claim.
3. Unless otherwise provided for by this Chapter, a dispute resolution body shall resolve an appeal to the extent of the subject of
the dispute appealed with the Revenue Service.
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4. A dispute resolution body or its staff may request that the appellant or the tax authority produce additional
information/documents about the appeal, at which time the proceedings for resolving the appeal shall be suspended.
5. The appeal shall be resolved with the participation of the appellant.
6. The dispute resolution bodies may resolve an appeal remotely, using the technical means. They may also resolve the appeal in
the absence of the appellant if the available case materials fully establish the factual circumstances related to the subject of the
dispute.
7. The appellant shall be notified of the time and venue of an oral hearing of an appeal by any means at the disposal of the dispute
resolution body, including phone, registered mail or electronic mail, SMS, etc.
8. If the appellant cannot be contacted or found, or fails to appear at the oral hearing of the appeal, the appeal shall be heard in
absentia of the appellant.
9. The appellant may defend his/her interests personally or through his/her authorised representative.
10. During the hearing, the appellant and/or his/her representative may attend the hearing in person or remotely, by using a
technical device.
Law of Georgia No 83 of 5 January 2021 – website, 6.1.2021
Article 303 – Suspension of resolution of an appeal
1. A dispute resolution body may suspend, on its own initiative or based on a party’s reasonable petition, resolution of an appeal in
order to obtain additional information and/or documents.
2. While suspending the resolution of an appeal, a dispute resolution body may request that the appellant and/or the tax authority
produce additional information or documents on the matters to be resolved within the scope of the appeal.
3. If the request of a dispute resolution body cannot be satisfied within the fixed term, the dispute resolution body shall be notified
accordingly within a reasonable time.
4. The total duration of suspension of resolution of an appeal on the grounds of obtaining additional information and/or documents
shall not exceed 45 days.
5. If the session of the Dispute Resolution Council is not held, the Chairperson or Vice-chairperson of the Council or in their
absence – a member present at the session of the Council may make a decision on suspension of the appeal to be resolved at the
session for maximum of 30 days, notifying the appellant to that effect.
Article 304 – Decision of a dispute resolution body
1. A dispute resolution body may:
a) grant an appeal;
b) grant an appeal in part;
c) dismiss an appeal;
d) leave an appeal unresolved;
e) make an interim decision and suspend resolving of an appeal;
f) (Deleted – 14.7.2020, No 6817);
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2. The interim decision of a dispute resolution body shall be appealed along with the final decision.
21. If the appealed decision/tax notice has been issued in accordance with the decision made by a dispute resolution body, the
dispute resolution body shall make the decision to refuse to grant the appeal. The aforementioned issue shall be considered by the
body on the basis of the decision of which the appealed decision/tax notice was issued.
3. The acts issued by the tax authority, which served as the basis for the appeal decision shall be overturned pro rata to the
overturned part of the decision of the tax authority.
4. The decision of a dispute resolution body shall usually be sent to the parties electronically.
5. If the appealed decision of a dispute resolution body is overturned based on the disciplinary misconduct of an official of the
dispute resolution body, for adequate reaction to such a fact, the dispute resolution body authority shall report the information to
the competent authority to determine the responsibility of such a person.
6. If the basis for granting an appeal in full or in part by the Dispute Resolution Council is any record in the tax legislation of
Georgia that allows multiple interpretations, the decision of the Council shall contain a recommendation on introducing changes
to the normative act that shall be forwarded to the competent authority for follow-up.
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Article 305 – Appealing the decision
1. If the Revenue Service makes a decision unfavourable to the appellant, the appellant may, within 20 days after being served
with the decision, appeal the decision to the Dispute Resolution Council or court.
2. The appellant may appeal the decision of the Dispute Resolution Council within 20 days after being served with the decision, to
a court.
3. Lodging an appeal with the tax authority or any other public authority within the time limit fixed for lodging an appeal shall be
deemed as compliance with the time for appeal.
4. The burden of proof that the appellant has failed to observe the time limit for appeal rests with the tax authority.
5. Failure of the appellant to follow up the tax dispute within the fixed time limit shall be deemed as acknowledging the appealed
overdue tax liability.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Article 306 – Entry into force and fulfilment of the decision
1. A decision of a dispute resolution body shall take effect on the 21th day of serving it upon the appellant, unless appealed.
2. Fulfilling a decision of a dispute resolution body, that has taken effect, shall be binding.
3. An appellant may apply to a dispute resolution body, and provide it with information on hindering execution of the decision by
an administrative authority.
4. Failure to execute or unlawfully hindering execution of the interim or final decision of a dispute resolution body shall be
deemed disciplinary misconduct and entail responsibility as prescribed by the legislation of Georgia.
5. Execution of a decision may be postponed on the basis of a reasonable written request of the authority executing the decision
and by the decision of a dispute resolution body.
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
http://www.matsne.gov.ge 20000000005001016012
Article 307 – Clarification of the decision
1. The appellant and the tax authority may apply to the dispute resolution body for clarification of the decision made by the latter.
2. While clarifying its decision, a dispute resolution body shall observe the same time-frames that are fixed for appeal resolution.
3. Clarifications shall form an integral part of the decision and shall be sent to the persons and authorities involved in the dispute.
4. Once executed, the decision shall not be clarified.
Article 308 – Resumption of disputes
1. A dispute may be resumed within the system of the Ministry of Finance of Georgia only in the event of newly discovered or
newly revealed circumstances, within 6 years after the decision has been made.
2. Only the appellant shall be entitled to apply to a dispute resolution body for resuming the dispute.
3. Based on any newly discovered or newly revealed circumstance, the appellant shall apply to the dispute resolution body that
was the last body to have substantially reviewed the subject of the dispute indicated by the appellant.
SECTION XV
TRANSITIONAL AND CONCLUSIVE PROVISIONS
Chapter XLIII – TRANSITIONAL AND CONCLUSIVE PROVISIONS
Article 309 – Transitional provisions
1. (Deleted – 20.12.2012, No 118).
2. (Deleted – 20.12.2012, No 118).
3. (Deleted – 20.12.2012, No 118).
31. (Deleted – 13.5.2016, No 5092).
32. (Deleted – 13.5.2016, No 5092).
33. (Deleted – 13.5.2016, No 5092).
4. (Deleted – 20.12.2012, No 118).
5. (Deleted – 8.11.2011, No 5202).
6. (Deleted – 18.12.2015, No 4680).
7. (Deleted – 26.12.2013, No 1886).
8. (Deleted).
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9. (Deleted).
10. (Deleted – 28.6.2019, No 4906).
101. The processing customs procedures (except for an inward processing procedure) shall not apply to oil product waste (to bilge
water (petroleum-contaminated water) and/or waste water after washing oil-storage tanks and reservoirs) provided that the
processed product is exported from the territory of Georgia.
11. (Deleted – 28.6.2019, No 4906).
12. Supply of goods/provision of services by a partnership established before 7 August 2009 to its member in return for an interest
shall not be subject to VAT and profit tax.
13. The Government of Georgia shall be assigned to prepare, upon making changes in the Forest Code of Georgia in the types of
forest management in connection with the lands occupied by hunting undertakings, the relevant changes regarding imposing
property tax on such lands.
14. The bad debt arising from economic activity conducted within the occupied territory shall be written off in agreement with
the Government of Georgia, without regard to the documents set forth in Article 8(29)(a-d) of this Code.
15. Until 1 January 2028, a natural person not using hired labour and conducting economic activity from a movable point of sale,
including a counter, located on the territory of a market (bazaar), except for a person who has been granted the status of a small
business, or who has been registered or is obliged to get registered as a VAT payer under this Code shall be exempted from the
obligation to use a cash register.
16. In the case of the organisation of betting house games in the systemic and electronic form, the object of income/profit taxation
for a person with regard to the said activity shall be the sum of the bets accepted during each accounting month, which is subject
to taxation at a 7% rate (except for the income/profit received by the organiser of the betting house games in the systemic and
electronic form as a result of participation of foreign citizens in the betting house games organised in the systemic and electronic
form). In such a case, the person shall submit a tax return in the form established by the Minister of Finance of Georgia not later
than the 15th day of the month following the accounting month, and shall pay the appropriate tax within the same period.
17. If a tourist zone business entity transfers a hotel built by the investment of such business entity, the provisions of Article
18(11)(c), Article 99(1)(q) and Article 99(2), and Article 206(1)(ee) shall apply to a new owner.
18. The privileges established under Article 99(1)(q) and paragraph 17 of this article shall not apply if a tourist zone business entity
or a new owner that acquired such a hotel built by the investment of such business entity does not ensure the functioning of the
hotel.
19. (Deleted – 28.6.2019, No 4906).
20. (Deleted – 28.6.2019, No 4906).
21. (Deleted – 28.6.2019, No 4906).
22. (Deleted – 28.6.2019, No 4906).
23. (Deleted – 14.7.2020, No 6817).
24. Until 1 January 2028, a natural person conducting the activity under Code 55.2 of the Foreign Economic Activity National
Commodity Nomenclature, namely letting living space owned by him/her for a short period, shall be taxable at a fixed income tax
rate in the event of applying to the tax authority, if he/she is not voluntarily registered as a VAT payer or the total sum of the
transactions performed by him/her in this part of activity in any 12 continuous calendar months does not exceed GEL 100 000.
25. For the part of activity provided for in paragraph (24) of this article, the living space, intended for letting for a short period,
shall be an income tax object of taxation for a natural person.
26. The fixed income tax shall be determined according to the object of taxation (room) and shall amount to GEL 10 per m2 in a
calendar month. Depending on the location of the object of taxation and/or seasonality, the Government of Georgia may reduce
and/or increase the fixed income tax rate based on the application by the local self-government authority.
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27. The fixed rate income tax, according to objects of taxation, shall be paid:
a) for the period from 1 January through 31 March – by no later than 15 April;
b) for the period from 1 April through 30 June – by no later than 15 July;
c) for the period from 1 July through 30 September – by no later than 5 October;
d) for the period from 1 October through 31 December – by no later than 15 January.
Note: At the same time, the assessed fixed rate income tax shall not be subject to subsequent recalculation.
28. Transition to the fixed rate income tax shall be performed based on the taxpayer’s application. The period of levying the fixed
rate income tax may cover either a full calendar year or one or more calendar month(s) that may not be continuous.
29. During the period of levying the fixed rate income tax:
a) in connection with letting living space by a natural person for a short time, a person engaged in hired labour shall be exempt
from income tax, correspondingly, a person letting living space for a short time – from a tax agent’s obligation;
b) the tax privileges under this Code shall not apply to the income tax with respect to the fixed rate income tax;
c) a natural person shall be released from the obligation to use a cash register.
30. If in the period of levying fixed rate income tax the object of taxation of the fixed rate income tax under paragraph (24) of this
article is leased out and the lessee uses the property for the same type of activity:
a) the lessee shall be exempt from profit/income tax on the income from letting the living space for a short time;
b) in connection with letting a living space by a lessee for a short time, a person engaged in hired labour shall be exempt from
income tax, correspondingly, a lessee – from a tax agent’s obligation;
c) the lessee shall be released from the obligation to use a cash register for such activity.
31. The Minister of Finance of Georgia shall define the procedure of transition to the fixed rate income tax and of tax reporting.
32. Letting a living space by a natural person for a short time in the period of levying fixed rate income tax on such a person shall
not be deemed as a VAT taxable transaction.
33. From 1 January 2011, natural persons shall not be subject to the fine provided for under Article 274 of this Code for violation
of the time limit for filing a property tax return for 2007 on the object of taxation provided for by Article 203 of this Code.
34. The object of taxation (parcel of land) calculated pro rata to the co-owned area of a natural person residing in an apartment
house shall be fully exempt from property tax in 2011.
35. For the purposes of profit and property taxes, the norms of the Tax Code of Georgia effective before 1 January 2010 shall apply
to depreciable fixed assets leased before 1 January 2010.
36. (Deleted – 14.7.2020, No 6817).
37. Notwithstanding the requirements of Article 252 of this Code, the following shall be written off:
a) an acknowledged tax liability, which incurred before 1 January 2013 and remains outstanding at the moment of its write-off,
and the surcharge assessed on it, if the person has not submitted to a tax authority any tax return/calculation (except for the
person’s property tax return/calculation, and a declaration and/or assessment made in accordance with Article 1761(1) or Article
309(58) and (59) of this Code) for any period after 1 January 2013 (before the amounts are written off), or if the tax amount to be
charged as payable based on the tax return/calculation (except for the person’s property tax return/calculation and a declaration
and/or assessment made in accordance with Article 1761(1) or Article 309(58) and (59) of this Code) submitted to the tax
authority equals zero (except where the amount of the total income under the submitted tax return/calculation exceeds zero
and/or the amount deductible exceeds the amount assessed); the procedure for writing off the tax liability as provided for by this
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subparagraph shall be applied until 1 January 2021;
a1) an acknowledged tax liability, which incurred before 1 January 2013 and exists for the moment of its write-off, and the
surcharge assessed on it, if the person has not submitted to a tax authority any tax return/calculation (except for the person’s
property tax return/calculation, and a declaration and/or assessment made in accordance with Article 1611(1) or Article 309(58)
and (59) of this Code) for any period after 1 January 2013 (before the amounts are written off), or if the tax amount to be charged
as payable based on the tax return/calculation (except for the person’s property tax return/calculation and a declaration and/or
assessment made in accordance with Article 1611(1) or Article 309(58) and (59) of this Code) submitted to the tax authority equals
zero (except where the amount of the total income under the submitted tax return/calculation exceeds zero and/or the amount
deductible exceeds the amount assessed);
b) (Deleted – 21.7.2018, No 3263);
c) a penalty imposed/charged before 1 January 2013 on a natural person under Article 281 of this Code and Article 139 of the Tax
Code of Georgia that was in force until 1 January 2011 and still outstanding by the time of entry into force of this paragraph;
d) an acknowledged tax liability of a natural person, which incurred before 1 January 2021 and remains outstanding at the
moment of its write-off, and the surcharge assessed on it.
38. The salaries accrued but not paid by 1 January 2008 shall be subject to 12% income tax.
39. (Deleted – 22.6.2012, No 6547).
40. (Deleted – 1.5.2015, No 3581).
41. (Deleted – 13.5.2016, No 5092).
42. (Deleted – 12.11.2025, No 1061).
43. (Deleted – 20.12.2012, No 118).
44. (Deleted – 14.7.2020, No 6817).
45. Notwithstanding the requirements of Article 252 of this Code, the Revenue Service may write off, under the procedure
established by the Minister of Finance of Georgia, any overdue tax liability, and fines and penalties assessed on it, if the liability is
not deemed acknowledged under the legislation of Georgia, or the taxpayer has not been served with any notice of a tax
authority/Tax Notice regarding the assessment of the tax liability amount, and the limitation period for serving the notice has
expired.
46. The tax treatment of international carriage and related services (including forwarding) in the course of tax audit of tax
period(s) from 1 January 2005 to 1 June 2006 shall be defined taking into consideration the amendments made to the Tax Code of
Georgia (Legislative Herald of Georgia, No 41, 30.12.2004, Art. 200) under Law of Georgia No 2955 of 28 April 2006 (Legislative
Herald of Georgia, No 11, 1.5.2006, Art. 84). This paragraph shall not apply to the overdue tax liabilities assessed and
acknowledged as per a tax audit completed prior to coming in force of this paragraph.
47. The 10-year loss carryover period defined by Article 122 of this Code shall apply to the loss incurred in 2010 and in subsequent
years.
48. Article 142(4) of this Code shall not apply to amounts assessed and unpaid prior to 1 January 2011.
49. The tax treatment of revenues received/receivable in the form of contractual penalties and other fines in the course of tax
audits of any tax period(s) subsequent to 1 January 2006 shall be defined taking into consideration Article 136(13) of this Code.
This paragraph shall not apply to overdue tax liabilities assessed and acknowledged per a tax audit completed prior to coming into
force of this paragraph.
50. Notwithstanding the requirements of Article 252 of this Code, the following shall be written off in the manner provided for by
the Minister of Finance of Georgia:
a) the property tax assessed on and unpaid for the property in the territories established by the Law of Georgia on Occupied
Territories, the penalty interest and fines assessed on it;
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b) the property tax assessed on and unpaid for the land possessed/owned by a person, the penalty interest and fines assessed on it, if
the land is situated in territories adjacent to the territories established by the Law of Georgia on Occupied Territories, due to
which the person cannot use the land, as evidenced by a certificate issued by a local self-government authority;
c) the property tax assessed on and unpaid for property possessed/owned by a person and parcels of land attached to it, the penalty
interest and fines assessed on it, if such a person cannot use such property due to the property being used as a dwelling for IDPs,
and if the property has been registered as a unit of compact (organised) accommodation of IDPs, as evidenced by a certificate
issued by the Ministry of Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs Georgia.
51. If a natural person fulfils the obligation to declare property tax on agricultural land before 1 January 2014, he/she shall be
released from the corresponding fine established by this Code.
52. In connection with the tax audit of any tax period(s) prior to the establishment by the competent authority of a maximum
marginal rate of loss:
a) the rate of loss established by the competent authority shall apply only if in such tax period the taxpayer used a higher loss rate
than that established by the competent authority;
b) if in such tax period the taxpayer used a loss rate equal to or lower than that established by the competent authority, a shortage
within the loss rate applied shall not be deemed as a shortfall;
c) no consideration shall be given to the adjustment of tax liability in connection with the taxpayer applying a maximum marginal
rate of loss, subsequent to the establishment of the loss rate, if the taxpayer used the loss rate lower than that established by the
competent authority or did not use it at all.
53. Paragraph (52) of this article shall not apply to overdue tax liabilities assessed and acknowledged per tax audits completed prior
to coming into force of this paragraph.
54. Goods imported for military exercise under the Memorandum on Facilitation of Crossing Border by Civil Transport of Vital
Importance, signed in Brussels on 30 October 2007, shall be exempt from import duties.
55. The tax liabilities, privileges and restrictions of an investor and contractor under the Law of Georgia on Olympic Movement
Promotion shall be determined by this Code and the Law of Georgia on Olympic Movement Promotion.
56. In the cases provided for by the Law of Georgia on Olympic Movement Promotion, the representative body of local self-
government may, within the scope of its authority, introduce a local tax rate different from the one fixed by this Code on a part of
the territory of the self-governing unit, within the limits of marginal rates fixed by an ordinance of the Government of Georgia.
57. Articles 82(1)(gg) and (gg1), 99(1)(u), 153(5 1), 1611(2), 1651(3)(d), 1652(2)(d), 168(5), 205(10 1), 206(1)(gg4) and 272(3 1) of this
Code shall not apply to persons engaged in the electricity distribution activity under the Law of Georgia on Power Engineering
and Natural Gas.
58. The interests not reimbursed to a natural person (except for a person registered as a VAT payer at the moment of receiving
income) or a non-resident enterprise (except where the income belongs to a non-resident’s permanent establishment in Georgia):
a) by the end of 2012, which are deducted as expenditure in the tax period of 2006, shall be deemed for tax purposes to be
reimbursed at the end of 2012;
b) by the end of 2012, which are deducted as expenditure in the tax period of 2007, shall be deemed for tax purposes to be
reimbursed till 1 July 2013;
c) by the end of 2013, which are deducted as expenditure in the tax period of 2008, shall be deemed for tax purposes to be
reimbursed at the end of 2013;
d) by the end of 2014, which are deducted as expenditure in the tax period of 2009, shall be deemed for tax purposes to be
reimbursed at the end of 2014;
e) by the end of 2015, which are deducted as expenditure in the tax period of 2010, shall be deemed for tax purposes to be
reimbursed at the end of 2015.
59. Where so provided for by paragraph (58) of this article, a person shall have a tax agent’s obligation and the obligation to be
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taxed by 5 per cent of the corresponding amount, and if actually reimbursed in the subsequent period, the respective income shall
not be taxable at the payment source.
60. (Deleted –13.5.2016, No 5092).
61. The penalty on the outstanding part of a tax liability between 1 January 2013 and 30 June 2015 shall be assessed in the amount
of 0.06%, and the penalty under Article 272(4) of this Code in the amount of 0.05% shall be assessed on the outstanding part of a
tax liability as from 1 July 2015. In this case, provisions of Article 269(2) and (2 1) of this Code shall not apply when defining the
amount of penalty for non-payment of the tax.
62. The limitation period defined under Article 4(1), (3), (5), (8) and (9) of this Code and the period defined under Article 43(1)(f)
and Article 72 (3) of this Code shall be:
a) within the period from 1 January 2015 to 1 January 2016 – 5 years;
b) within the period from 1 January 2016 to 1 January 2017 – 4 years.
63. (Deleted – 14.7.2020, No 6817).
64. A tax agreement concluded on the basis of a decision made before 31 December 2013 shall retain legal force and shall be
subject to the provisions of Chapter XLI of the Tax Code of Georgia that was in force at the time when the decision in question
was made.
65. The amount paid within the scope of the state financing provided under Article 10 of the Law of Georgia on State Support for
National Cinematography shall be recognised as income at the moment of accepting a national film for operation, but not later
than the preparation of an act on the completion of the film and the moment of confirming the fact that the financing was spent
according to the intended purpose.
66. A person shall record a national film produced with the support of state financing under the Law of Georgia on State Support
for National Cinematography as an intangible asset. The person may fully deduct depreciation charges on the intangible asset from
the moment of accepting the film for operation.
67. A person who produces a film with the support of state financing under the Law of Georgia on State Support for National
Cinematography, shall be obligated to:
a) select the deduction rate for the depreciation charges on an intangible asset in the year when the asset was put into operation
and shall not change the selected rate of deduction for the given asset in the periods following the tax year when the asset was put
into operation;
b) in the case of full deduction of depreciation charges, use the same method for all the subsequently produced national films,
however, he/she may change the selected full deduction of the depreciation charges after five years from the moment of selection.
68. (Deleted – 14.7.2020, No 6817).
69. (Deleted – 14.7.2020, No 6817).
70. (Deleted – 14.7.2020, No 6817).
71. (Deleted – 14.7.2020, No 6817).
72. (Deleted – 14.7.2020, No 6817).
73. (Deleted – 14.7.2020, No 6817).
74. (Deleted – 14.7.2020, No 6817).
75. (Deleted – 14.7.2020, No 6817).
76. (Deleted – 14.7.2020, No 6817).
77. (Deleted – 14.7.2020, No 6817).
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78. (Deleted – 14.7.2020, No 6817).
79. Supply of immovable property and delivery by the supplier of immovable property of construction and installation services
related to the property supplied shall be VAT exempt with the right to deduct if all of the following conditions are met:
a) the immovable property is supplied and the related construction and installation services are delivered within the period from 1
January 2015 to 1 January 2029;
b) the supplied immovable property is located within the facility that meets one of the following conditions:
b.a) the facility is provided for by a construction permit which was valid on 8 August 2008;
b.b) the design documentation (architectural design) for the facility was agreed upon with an authorised body, as of 8 August 2008,
but the construction permit was issued later on;
b.c) the design documentation (architectural design) for the facility provided for by subparagraph b.a) or b.b) of this paragraph was
changed, or the existing building was taken down and a new construction permit was issued during the period following 8 August
2008;
c) the supplier of the immovable property is the holder of the construction permit issued for the facility specified in sub-paragraph
b) of this paragraph (he/she may not be the holder of the construction permit/the design documentation (architectural design)
specified in sub-paragraph (b) of this paragraph);
d) an authorised body issues, before 1 January 2029, an individual administrative-legal act to put into operation the facility where
the supplied immovable property is located;
e) the facility where the supplied immovable property is located is intended for living;
f) the facility where the supplied immovable property is located is included in the list under paragraph 81 of this article.
Note: for the purpose of this paragraph, if within the period from 8 August 2008 to 1 January 2015 the right of ownership to
immovable property, as a facility under construction, located in a facility included in the list under paragraph 81 of this article was
registered with the Public Registry in the name of a purchaser, construction and installation services delivered by the property
supplier in connection with this property shall be considered as part of the immovable property supply, and the moment of
completing the construction and installation services shall be considered as the time of supply.
80. The construction and installation services rendered in connection with a facility included in the list under paragraph 81 of this
article to a person supplying the immovable property which, under paragraph 79 of this article, is VAT exempt with the right to
deduct shall be VAT exempt with the right to deduct.
81. To enjoy the privileges provided for in paragraphs 79 and 80 of this article, the list of facilities that meet the requirements set
in paragraph 79(b) and (e) of this article shall be compiled by an executive body of the municipality.
811. A person may apply to a municipal executive body for entering a facility in his/her possession in the list under paragraph 81
of this article. The municipal executive body shall enter this facility in this list if, upon application to it by the person, this facility
meets the requirements of paragraph 79(b) and (e) of this article.
812. Based on the tax privileges under paragraphs 79 and 80 of this article, the period of limitation under Article 4 of this Code of
the respective accounting period for an exempt taxable transaction conducted within the accounting periods between 1 January
2015 and 1 January 2026 shall be:
a) fourteen years for an exempt taxable transaction conducted within the accounting period from 1 January 2015 to 1 January
2016;
b) thirteen years for an exempt taxable transaction conducted within the accounting period from 1 January 2016 to 1 January
2017;
c) twelve years for an exempt taxable transaction conducted within the accounting period from 1 January 2017 to 1 January 2018;
d) eleven years for an exempt taxable transaction conducted within the accounting period from 1 January 2018 to 1 January 2019;
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e) ten years for an exempt taxable transaction conducted within the accounting period from 1 January 2019 to 1 January 2020;
f) nine years for an exempt taxable transaction conducted within the accounting period from 1 January 2020 to 1 January 2021;
g) eight years for an exempt taxable transaction conducted within the accounting period from 1 January 2021 to 1 January 2022;
h) seven years for an exempt taxable transaction conducted within the accounting period from 1 January 2022 to 1 January 2023;
i) six years for an exempt taxable transaction conducted within the accounting period from 1 January 2023 to 1 January 2024;
j) five years for an exempt taxable transaction conducted within the accounting period from 1 January 2024 to 1 January 2025;
k) four years for an exempt taxable transaction conducted within the accounting period from 1 January 2025 to 1 January 2026.
82. (Deleted – 28.6.2019, No 4906).
83. The exemption from liability provided for by paragraph 82 of this article shall not apply to persons against whom the tax
sanctions imposed for tax offences were enforced before the entry into force of paragraph 82 of this article.
84. A document confirming the payment of VAT into the budget at the time of reverse charge or temporary admission of goods
shall be deemed to be a deduction document for the reporting periods before 1 July 2015.
85. The Minister of Finance of Georgia shall ensure issuance of an order to establish the procedure specified in Article 81(5) of this
Code before 1 January 2016.
86. Waiver by an electricity enterprise engaged in electricity distribution of a debtor’s debt incurred as a result of the supply of
electricity during the periods from 13 June 1997 to 1 January 2000 and from 1 November 2001 to 1 January 2005 shall not be
deemed as the reimbursement of the cost of the received goods.
87. The following shall be exempted from income tax:
a) a benefit received by a natural person as a result of the waiver of the debt incurred as a result of the supply of electricity during
the periods from 13 June 1997 to 1 January 2000 and 1 November 2001 to 1 October 2005;
b) a benefit received by a person affected by the natural disaster occurring in Tbilisi on 13-14 June 2015:
b.a) as a result of waiver of loan by a financial institution;
b.b) as a result of receiving goods/services free of charge from 14 June 2015 to 1 January 2016;
c) the benefit received by a natural person as a result of waiving (writing off) the loan granted to the natural person before 1
January 2019, and the interest and the penalty accrued on the loan if the appropriate obligation of the aforementioned natural
person has been waived (written off) by a commercial bank or a microfinance organization.
Note:
1. For the purposes of subparagraph (b) of this paragraph, the list of persons affected by the natural disaster that occurred in Tbilisi
on 13-14 June 2015 shall be compiled by the government of the Tbilisi municipality.
2. Sub-paragraph c) of this paragraph shall not apply to the cases of waiver by an employer of a loan obligation of an employee or
of the related persons defined under Article 19 of this Code.
871. A benefit received by a student through a sum paid by the Ministry of Education, Science and Youth of Georgia in order for
the said Ministry to redeem the tuition fees as of 1 August 2023 to be paid to educational institutions operating in Georgia in the
form of a legal entity under private law by the students with financial liabilities/their status suspended on the ground of financial
liabilities, and a benefit received by a student through writing off by an educational institution of the tuition fee to be paid as of 1
August 2023 by a student with financial liability/his/her status suspended on the ground of financial liability shall be exempted
from payment of income tax.
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88. A financial institution may deduct from the total income the value of the loan (waived) under paragraph 87(b.a) of this article.
The value of the loan (waived) under paragraph 87(b.a) of this article need not be included in the total income by the financial
institution.
881) A commercial bank or a microfinance organisation may deduct the amount waived (written off) for a natural person, as
provided for in paragraph 87(c) of this article, from the gross income, except when:
a) the reserve of a potential loan loss has been deducted from the gross income for a respective period;
b) the interest and the penalty accrued on the loan has not been included in the gross income for a respective period.
Note: Based on the limitation defined in this paragraph, the value of an obligation waived (written off) for a natural person, as
provided for in paragraph 87(c) of this article, shall not be subject to inclusion by a commercial bank or a microfinance
organisation in the gross income.
89. If the Government of Georgia, in accordance with the treaty put in effect after the ratification by the Parliament of Georgia,
has an obligation to make exemption from or to undertake the fulfilment of tax liabilities arisen from supply of goods and/or
providing services (except where it is directly determined in the treaty that tax liabilities are fulfilled by the Government of
Georgia) the supply of goods and/or provision of services within the scope of the said treaty shall be deemed exempt from VAT
with the right of deduction and the income from conducting such operations shall be exempt from income/profit tax.
90. Gratuities transferred by an enterprise/entrepreneur to the State and/or self-government unit in relations with natural disaster
which took place in 13-14 June 2015 in Tbilisi, shall be subject to deduction from gross income.
91. Tax privileges under Article 82(2)(a.f) of this Code that are valid until 1 January 2016 shall apply to persons under the same
subparagraph residing in towns, villages, communities and small settlements (except for settlements included in the list of high-
mountain settlements approved by Ordinance No 671 of 30 December 2015 of the Government of Georgia on Approval of the List
of High-mountain Settlements) specified in the list defined under the appendix to the law provided for in Article 6 of the Law of
Georgia on Socio-economic and Cultural Development of High-mountain Regions valid until 1 January 2016.
92. If a resident enterprise (except as provided for by paragraph 142 of this article) distributes a dividend from a net profit gained
during the reporting periods from 1 January 2008 to 1 January 2017, it may set off the amount of profit tax assessed and paid based
on the reporting periods, but not more than the amount to be paid according to the object of profit taxation provided for under
Article 981 of this Code.
921. The distribution of profit gained by the permanent establishment of a non-resident enterprise before 1 January 2017 shall not
be subject to profit taxation.
93. The amount to be set off under paragraph 92 of this article shall be calculated by the following formula – A x B / (C – D),
where: A is the amount to be distributed as a dividend; B is the amount of profit tax assessed and paid according to the reporting
periods from 1 January 2008 to 1 January 2017; C is the amount of net profit gained during the reporting periods from 1 January
2008 to 1 January 2017; D is the value of the shares/interest of an enterprise transferred to a partner by the enterprise instead of a
dividend based on the net profit gained during the reporting periods from 1 January 2008 to 1 January 2017.
931. In the case under Article 982(3)(f) of this Code, a person may, in accordance with paragraph 92 of this article, set off the
profit tax imposed and paid before the distribution of dividends for the accounting periods from 1 January 2008 to 1 January 2017.
932. If a person enjoys the right under paragraph 931 of this article:
a) at the time of the distribution of dividends for the accounting periods from 1 January 2008 to 1 January 2017, the offset under
paragraph 92 of this article shall be decreased by the amount of the profit tax set off in accordance with paragraph 931 of the
same article;
b) at the time of receiving the compensation as a result of providing the right to participate in the capital (shares/interest) (actually
receiving the sum), a person may set off the previously paid profit tax within the accounting period when the sum was actually
received but not more than the profit tax calculated according to the sum compensated.
94. Banking institutions, credit unions, microfinance organisations or loan providers shall be subject to profit tax according to the
objects of taxation under Article 97(12) of this Code from 1 January 2023.
1
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94 . An insurance organisation shall be subject to profit tax according to the object of taxation under Article 97(1) of this Code
from 1 January 2024.
95. Until 1 January 2023, the object of profit taxation for commercial banks, credit unions, insurance organisations, microfinance
organisations and loan providers shall be the difference between the gross income gained during a calendar year and the deduction
amounts under this Code.
951. Until 1 January 2024, the object of profit taxation for an insurance organisation shall be the difference between the gross
income gained during a calendar year and the deduction amounts under this Code.
952. Before 1 January 2024, a legal person conducting licensed insurance activities shall be entitled to deduct from the gross
income of a reporting year the ‘insurance/actual damage, net’ for the same reporting year, as calculated under the procedure
established by the National Bank of Georgia, except for the income gained from recourse and survival property.
96. (Deleted – 14.7.2020, No 6817).
97. The rate for mobile communication services under Article 188(3) of this Code shall be 8 % until 1 January 2017, and 3 % –
from 1 January 2017 till 1 January 2018.
98. The time of performing a taxable transaction involving goods supplied/services provided within a period after 1 January 2017
for which the compensation/part of the compensation was paid before 1 January 2017 (before supply of goods/provision of
services) shall be considered the moment of supplying goods/providing services. In addition, the compensation/part of the
compensation paid within a period after 1 January 2017 on the same transaction before supply of goods/provision of services shall
be subject to VAT assessment under Article 163(2) of this Code.
99. For the purposes of Article 98 1 of this Code:
a) the distribution of dividends from profits attributed to the periods subsequent to 1 January 2008 and received from a person
under paragraph 94 of this article shall not be considered as the distribution of profit;
b) the distribution of dividends from profits attributed to the periods subsequent to 1 January 2008 to a person under paragraph 94
of this article shall be considered as the distribution of profit.
991. For the purposes of Article 981 of this Code:
a) the distribution of dividends from profits attributed to the periods from 1 January 2008 to 1 January 2024 and received from
persons provided for by paragraph 94 1 of this article shall not be considered as the distribution of profit;
b) the distribution of dividends from profits attributed to the periods from 1 January 2008 to 1 January 2017 to persons provided
for by paragraph 941 of this article, and the distribution of dividends from profits attributed to the periods from 1 January 2017 to
1 January 2024 to persons provided for by paragraph 941 of this article before 1 January 2024 shall be considered as the
distribution of profit.
992. Dividend paid by a resident enterprise shall not be taxed at source and shall not be included in the gross income of a
beneficiary of dividend if the resident enterprise has received the dividend as a result of the distribution of profit for 2023 or the
periods following that year by the person provided for by paragraph 94 of this article.
100. Until 1 October 2019, a motor car under the commodity item 8703 of the National Commodity Nomenclature of Foreign
Economic Activities shall be taxed at an excise rate effective until 1 June 2019 if:
a) transportation of the motor car by sea has started before 1 June 2019, and it is delivered to the customs territory of Georgia by
the sea transport not later than 31 August 2019;
b) the motor car is delivered to the customs territory of Georgia before 1 June 2019.
101. Co-financing received by a person from the Legal Entity under Public Law within the system of the Ministry of Economy and
Sustainable Development of Georgia – Produce in Georgia under Ordinance No 365 of 30 May 2014 of the Government of Georgia
on Approval of the State Programme ‘Produce in Georgia’ throughout the duration of this ordinance, within the micro and small
entrepreneurship part of the State Programme ‘Produce in Georgia’ shall not be included in the gross income.
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102. In the case of enjoying the tax privileges under Article 99(1)(f) and (q) of this Code that are effective during the respective
accounting period, the period of limitation under Article 4 of this Code of the respective accounting period for the accounting
periods of 2014-2016 years shall be extended by one year.
103. For the purposes of Article 98 1 of this Code (except as provided for by paragraph 1031 of this article):
a) the distribution of dividend from the net profit earned during the accounting period from 1 January 2008 to 1 January 2017
shall be deemed as the distribution of profit, whereas its subsequent distribution by the recipient of the dividend – the person
defined under Article 2(3) of the Law of Georgia on Entrepreneurs (except for an individual enterprise and a person exempted
from profit tax under this Code) shall not be deemed as the distribution of profit;
b) the subsequent distribution of dividend received during the accounting periods before 1 January 2017 shall not be deemed as
the distribution of profit.
1031. For the purposes of Article 981 of this Code:
a) the distribution of dividend from the net profit received by an insurance organisation during the accounting period from 1
January 2015 to 1 January 2024 shall be deemed as the distribution of profit;
b) the subsequent distribution of dividend received by an insurance organisation during the accounting periods before 1 January
2024 shall not be deemed as the distribution of profit.
104. An object of profit taxation of an enterprise shall be the difference between the gross income gained during a calendar year
and the deduction amounts provided for by this Code if the enterprise has been granted the status of person under paragraph 94 of
this article during the respective calendar year (it has been established that it is the person under paragraph 94 of this article). In
such a case:
a) accruals carried out on the basis of a profit tax return submitted according to the object of taxation under Article 97 of this Code
during the respective calendar year shall be cancelled:
b) current payments payable according to the periods under Article 155 of this Code for the period before acquiring the status of
person under paragraph 94 of this article (before being declared a tax payer of this category) shall not be imposed.
105. An object of profit taxation of an enterprise shall be the difference between the gross income gained during a calendar year
and the deduction amounts provided for by this Code if the enterprise has lost the status of person under paragraph 94 of this
article during the respective calendar year (it has been established that it is not the person under paragraph 94 of this article).
106. If an enterprise taxed according to the objects of taxation under Article 97(1) and (3) of this Code since 1 January 2017 was
established during the period from 1 December 2016 to 31 December 2016, its first taxation period shall be the period from the day
it was established till the end of 2016, according to which it shall submit the profit tax return to the tax authority before 1 April
2018.
107. For VAT taxation purposes, provisions effective until 1 January 2018 shall apply to long-term contracts concluded before 1
January 2018.
108. A person having the status of a small business shall file a tax return for the period from 1 January 2018 to 1 July 2018 to a tax
authority not later than 1 April 2019.
109. An entrepreneur natural person, who has been granted the status of a small business within the period from 1 January 2018 to
1 July 2018, shall file a tax return for an incomplete tax period (for a period from 1 January 2018 until the month when the status
was granted) to a tax authority not later than 1 April 2019.
110. A penalty under Article 274 of this Code for violation of the time limit determined for filing a tax return under Article 93(1 1
) of this Code for the accounting periods from 1 January 2018 to 1 January 2019 with a tax authority shall not be imposed on a
person having the status of a small business;
111. (Deleted – 12.11.2025, No 1061).
112. Within 6 calendar months from 1 May 2020, and within 6 calendar months from 1 December 2020, an employer may reduce
(not pay to the budget) its payable income tax deducted from a salary of up to GEL 750 paid to an employee if the salary of the
employee received from this employer during one calendar month does not exceed GEL 1 500.
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Note: the tax privilege under this paragraph does not apply to:
a) a budgetary organisation;
b) the National Bank of Georgia;
c) a national regulatory body;
d) an enterprise more than 50% of the equity/shares of which is held by the state or a municipality;
e) an enterprise established by/a subsidiary enterprise of the enterprise provided for by paragraph d) of this note if this enterprise
holds more than 50% the equity/shares of the enterprise established thereby/its subsidiary enterprise.
113. A person may impose a VAT tax on rental/leasing services rendered during 6 calendar months (the accounting period) from 1
March 2020, and during 6 calendar months (the accounting period) from 1 December 2020, within the accounting period of actual
payment of the compensation amount/part of the compensation amount for the services.
114. The Minister of Finance of Georgia/Head of the Revenue Service shall have the right to extend for individual taxpayers the
deadline set by this Code for payment of income tax and/or property tax payable in 2020 (including in February, March, April and
May of 2020) until not later than 1 January 2021. In such a case, a surcharge provided for by this Code shall not be charged to a
taxpayer.
1141. The Minister of Finance of Georgia/head of the Revenue Service shall have the right to extend the deadline set by this Code
for payment of income tax payable in November and December of 2020 until not later than 1 July 2021 for a taxpayer who
performs activities provided for by paragraph 115(a) of this article in urban-type settlement (daba) of Bakuriani of the Borjomi
municipality, village Gudauri of the Kazbegi municipality, resort goderdzi located in the Khulo municipality or in urban-type
settlement (daba) Mestia of the Mestia municipality. In such a case, the surcharge provided for by this Code shall not be charged
on the taxpayer.
115. The property used in the activities under the below Codes of the Foreign Economic Activity National Commodity
Nomenclature (სეკ 006-2016) shall be exempt from the property tax to be declared in 2020 or 2021 under this Code:
a) property used in the activities provided for under Code 55.1 (hotels and similar accommodation facilities) and/or under Code
55.2 (rest and other short-term accommodation facilities);
b) property used in the activity provided for under Code 56.1 (restaurants and mobile food service activities);
c) property used in the activity provided for under Code 56.3 (beverage service activities);
d) property used in the activity provided for under Code 79 (travel agencies, tour operators and other reservation services and
related activities).
Note: the tax privilege under this paragraph shall also apply to the property transferred by rent, leasing or another similar way if
the property is used in any of the activities defined by the same paragraph.
1151. The property used in the activities defined by paragraph 115(a-d) of this article, except for land, shall be exempt from the
property tax to be declared in 2022 under this Code. In such a case, an enterprise/organisation shall not be exempt from payment
of the property tax provided for by Article 205(3) of this Code in the form of the current payment, and it shall be payable in the
amount of the annual tax payment for a previous tax year, irrespective of the tax privilege provided for by this paragraph, not later
than 15 June of a tax year.
Note: the tax privilege under this paragraph shall also apply to the property transferred by rent, leasing or another similar way if
the property is used in any of the activities defined by the same paragraph.
116. Provision of a tax authority with incorrect information, which has led to an unreasonable payment to an employee of the
compensation related to the spread of the novel coronavirus in Georgia as defined by Ordinance No 286 of 4 May 2020 of the
Government of Georgia on Approval of the Targeted State Programme for Mitigating the Damage Incurred as a Result of the
Infection (COVID-19) Caused by the Novel Coronavirus (SARS-COV-2), shall carry a fine for an employer in the amount of the
doubled compensation paid on the basis of the aforementioned information.
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117. If a lease agreement is concluded till 1 January 2022, the VAT taxable amount of the property lease out transaction shall be
the full amount of the lease payments under the agreement (including the benefit under the agreement), and the VAT taxation
shall be carried out in proportion to the amount payable, in stages, according to the accounting periods within which the
appropriate amount is to be paid. In addition, if the amount, fully or partially, is paid earlier than it is provided for by the
agreement, the VAT corresponding to the amount reimbursed shall be paid according to the accounting period of payment of this
amount.
118. An enterprise, which has been granted the status of a person provided for by paragraph 94 of this article (it has been
established that it is a person provided for by paragraph 94 of this article):
a) shall, under the procedure established by the Minister of Finance of Georgia, impose a profit tax on the distribution of dividends
in the accounting periods after receiving the appropriate status, from the net profit earned within the accounting periods from 1
January 2017 till the receipt of the status, when the person was subject to profit tax according to the objects of taxation under
Article 97(1) and (3) of this Code;
b) may, in the accounting periods after receiving the status, under the provisions of Article 982 and 983 of this Code, deduct and
refund under the procedure established by the same Code the amount of profit tax paid according to the accounting periods from 1
January 2017 till the receipt the status, when the person was subject to profit tax according to the objects of taxation under Article
97(1) and (3) of this Code. The procedure for deducting and refunding the amount of profit tax shall be defined by the Minister of
Finance of Georgia.
119. If an enterprise, which has lost the status of a person provided for by paragraph 94 of this article (it has been established that
it is no longer a person provided for by paragraph 94 of this article), distributes dividends in the accounting periods after losing the
status from the net profit earned in the accounting periods from 1 January 2017 until the loss of the status, when the person was
subject to profit tax according to the object of taxation provided for by paragraph 95 of this article, it shall be entitled to deduct the
amount of profit tax assessed and paid according to these periods, but not more than the amount payable according to the object of
profit taxation provided for by Article 981(1) of this Code.
120. The amount of profit tax provided for by paragraph 118 of this article deductible from the net profit earned in the accounting
periods when a person was subject to profit tax according to the object of taxation under paragraph 95 of this article shall be
calculated according to the following formula: A×B/(C-D), where A is the amount of a sum to be distributed as a dividend; B is the
amount of profit tax assessed and paid according to the accounting periods from 1 January 2017 until the loss of the status; C is the
amount of net profit earned in the accounting periods from 1 January 2017 until the loss of the status; D is the value of the
shares/interest of this enterprise transferred by the enterprise to its partner in return for a dividend at the expense of the net profit
earned in the accounting periods from 1 January 2017 until the loss of the status.
121. In customs proceedings provided for by the Customs Code of Georgia, for the purposes of Article 163(9) of the Customs Code
of Georgia, consideration shall be given to tax offences identified before 1 September 2019 on the basis of Articles 277, 279, 289
and 290 of this Code.
122. If tax liabilities of a taxpayer are written off under the procedure established by the tax legislation, and before the tax
liabilities are written off, payment of the amount of the aforementioned tax and the sanction, including in the form of
compensation for damage, has been imposed by the court decision on the same taxpayer and/or an authorised person for
administration/representation and/or on a founder in favour of the state/the state budget/a tax authority, a liability imposed by the
court decision and remaining outstanding shall be considered cancelled after the tax liabilities are written off and the enforcement
proceedings initiated on the basis of this liability shall be terminated.
123. Provisions provided for in Article 174(9 1) of this Code effective until 1 January 2021 shall apply to the cases of supplying
fixed assets purchased before 1 January 2021 in a period after 2021.
124. Before 1 January 2021, apart from the grounds under Article 61(2) of this Code, information on VAT assessment of the sale of
goods in the case provided for by Article 1761 of this Code shall also be the ground for the assessment of a tax.
125. The Minister of Finance of Georgia shall, have the right to define before 1 January 2021 certain cases when a tax authority
may cancel the registration of a person as VAT taxpayer. In such a case, the registration as VAT taxpayer shall be cancelled from
the date of the decision of the tax authority.
126. Until 1 January 2021, where so provided for by Article 54(2), (3) or (4) of the Customs Code of Georgia, the sum of import
shall be determined in compliance with the procedure established by the same paragraph for calculating the amount of import tax.
127. Until 1 January 2021, the following shall be exempted from VAT with the right of deduction:
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a) the supply of electricity and guaranteed capacity, except for the supply of electricity to a consumer provided for by the Law of
Georgia on Energy and Water Supply who buys electricity for own consumption, and the transmission and/or dispatching services;
b) the supply of goods manufactured in Georgia intended for the therapeutic/medical purposes. For the purpose of this
subparagraph, the list of goods intended for therapeutic/medical purposes shall be defined by a joint order of the Minister of
Internally Displaced Persons from the Occupied Territories, Labour, Health and Social Affairs of Georgia and the Minister of
Finance of Georgia.
128. Until 1 January 2021, except as provided for Article 174(3)(a-f) of this Code, VAT shall not be deducted on the basis of the
deduction documents provided for by Article 173(2)(e) and (g) of this Code, which are not included by the taxpayer
(buyer/beneficiary of deduction) in the VAT declaration submitted according to not later than the accounting period of December
of the calendar year of the taxable transaction from the end of the accounting period of a taxable transaction, or within not later
than 3 calendar years, in the adjusted declaration for the same period.
129. Until 1 January 2021, except as provided for Article 240(1-3) of this Code, a tax authority may take measures provided for by
Article 238(1)(a) and (c-f) of this Code against an authorised person selling the goods provided for by Article 1761(1) and (2) of
this Code if the person fails to fulfil the obligation under the same article to pay the amount of VAT to the budget.
130. A taxpayer may reduce (not pay to the budget) the due income tax deferred in accordance with paragraph 114 of this article
(income tax the deadline under this Code for payment of which has been extended) if he/she performs any of the activities
provided for in paragraph 115 of this article. The procedure for applying this paragraph shall be defined by an order of the
Minister of Finance of Georgia.
131. Article 1641(2) and Article 172(4)(z5) of this Code shall be applied when importing goods from 1 January 2028 on. In
addition, a VAT taxable amount at import of goods before 1 January 2028 (the value of goods for customs purposes) shall include,
apart from VAT, the import duties to be paid in Georgia, based on the import of goods.
132. Until 1 January 2028, the import of goods shall be exempt from VAT in accordance with the requirements of Article 199(d)
and (n) of this Code, considering the Note to the same article, except for the import of goods from a Free Industrial Zone.
133. Distribution of dividends from the net profit gained by a person organising a game of chance in a systemic and electronic
form from this activity during the accounting period before 1 January 2022 shall be considered as profit distribution and it shall be
subject to taxation under Article 97(10) of this Code.
134. Under Article 109 of this Code, as a result of revocation of the procedure for deducting possible loan loss reserves from the
gross income by bank institutions, credit unions or microfinance organisations, effective before 1 January 2023, the taxable
profit/income gained on the basis of the difference between the reserve balances created during the 2023 reporting period shall be
taxed at the rate of 15%. The Minister of Finance of Georgia shall have the right to define the procedure for applying this
paragraph.
135. Within the framework of the matches at the final stage of the 2023 Union of European Football Associations (the ‘UEFA’)
European Under-21 Championship and the related events:
a) the income earned by the UEFA and the Georgian Football Federation shall be exempt from income tax;
b) the supply of goods and/or rendering of services by the UEFA and the Georgian Football Federation shall be exempt from VAT
with the right of deduction;
c) the import of goods by the UEFA and the Georgian Football Federation shall be exempt from import payments;
d) the UEFA and the Georgian Football Federation shall be exempt from property tax on the property used in Georgia.
136. the income earned by the appointed person within the framework of the matches at the final stage of the 2023 UEFA
European Under-21 Championship and the related events shall be exempt from income/profit tax.
Note: the appointed person shall be any non-resident person appointed by the UEFA or the Georgian Football Federation,
including a member or a stuff member of a foreign national football team (e.g. a player, a coach, etc.), an employee of the UEFA or
the Georgian Football Federation.
137. The obligation of a tax agent provided for by Article 154 of this Code shall not apply to the UEFA and the Georgian Football
Federation within the framework of the matches at the final stage of the 2023 European Under-21 Championship and the related
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events. In addition, provision of services to the UEFA and the Georgian Football Federation within the framework of the
aforementioned events shall not be subject to VAT reverse charge.
138. The organisation and holding of the matches at the final stage of the 2023 UEFA European Under-21 Championship shall not
cause the setting-up of a permanent establishment in Georgia.
139. The following shall be exempt from VAT with the right of deduction:
a) the supply of goods and/or the rendering of services by a person to the UEFA, the Georgian Football Federation and/or the
appointed person, that are directly or indirectly related to the matches at the final stage of the 2023 UEFA European Under-21
Championship and the related events;
b) the sale of tickets for the matches at the final stage of the 2023 UEFA European Under-21 Championship and the related events.
140. The Minister of Finance of Georgia may define the procedure for enjoying the tax privileges provided for by paragraphs 135-
139 of this article.
141. Provisions defined by this Code relating to the relations provided for by the Law of Georgia on Voluntary Private Pension
shall apply to the payments to be made from 1 January 2025 by the legal entities that were engaged in the voluntary private
pension activities before 1 January 2025.
142. If an insurance organisation distributes a dividend from a net profit gained during the reporting periods from 1 January 2015
to 1 January 2024, it shall have the right to set off the amount of profit tax assessed and paid based on the reporting periods, but
not more than the amount to be paid according to the object of profit taxation provided for under Article 981 of this Code.
143. The amount to be set off provided for by paragraph 142 of this article shall be calculated according to the following formula –
A x B / (C – D), where: A is the amount to be distributed as a dividend; B is the amount of profit tax assessed and paid according to
the reporting periods from 1 January 2015 to 1 January 2024; C is the amount of net profit gained during the reporting periods
from 1 January 2015 to 1 January 2024; D is the value of the shares/interest of an insurance organisation transferred to a partner by
this insurance organisation instead of a dividend based on the net profit gained during the reporting periods from 1 January 2015
to 1 January 2024.
144. A tax authority may, in accordance with the procedure established by a subordinate normative act of the Government of
Georgia, write off an outstanding amount of a fee for the use of fresh groundwater for bottling purposes provided for by Article 5
of the Law of Georgia on Fees for the Use of Natural Resources, and an outstanding fine and surcharge to be paid by a person who
has not used a respective licence (with or without an appropriate approved development plan) before 1 December 2023, in
particular, has not bottled fresh groundwater. This paragraph shall apply to a person if either of the following conditions is met:
a) a person concerned no longer holds a licence issued for bottling fresh groundwater, as of 1 December 2023;
b) a person concerned will, before 1 April 2024, apply to a body issuing a licence for bottling fresh groundwater for revoking the
licence and will not use the said licence from 1 December 2023 to 1 April 2024 inclusive, in particular, will not bottle fresh
groundwater.
145. The Government of Georgia may establish the procedure provided for by paragraph 144 of this article.
146. If the right of ownership of all the assets (including shares/equity) of a foreign enterprise registered in a country with
preferential tax treatment is transferred to a Georgian enterprise before 1 January 2028:
a) the income/benefit received by the foreign enterprise and its partner natural person within that activity, which, for the purpose
of this Code, is deemed as an income received from a Georgian source, shall be exempted from profit/income tax;
b) bringing in/import of an asset/goods into Georgia shall be exempted from import tax. The procedure and conditions for applying
this subparagraph shall be defined by the Minister of Finance of Georgia;
c) with regard to an asset received within that activity, a Georgian enterprise shall be exempted from property tax until 1 January
2030.
147. Tax privileges of an innovation start-up, an innovation small and medium-sized company, subjects with the statuses of a
company providing research and development services, as provided for by the Law of Georgia on Innovations, shall be defined by
the Law of Georgia on Innovations.
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Note:
1. This paragraph shall apply if:
a) 100 per cent of shares/equity in a foreign enterprise registered in a country with preferential tax treatment and in a Georgian
enterprise is owned by the same natural person (group of natural persons);
b) such an asset has been transferred which is owned by a foreign enterprise registered in a country with preferential tax
treatment on the day when this paragraph becomes effective.
2. Where so provided for by this paragraph, the value of an asset for the recipient party of the asset shall be the same as its value
for the supplier party of the asset at the moment of transferring that asset.
Law of Georgia No 4061 of 15 December 2010 – LHG III, No 75, 27.12.2010, Art. 469
Law of Georgia No 4114 of 17 December 2010 – LHG III, No 76, 29.12.2010, Art. 506
Law of Georgia No 4206 of 22 February 2011 – website, 10.3.2011
Law of Georgia No 4549 of 19 April 2011 – website, 2.5.2011
Law of Georgia No 4720 of 31 May 2011 – website, 10.6.2011
Law of Georgia No 4754 of 14 June 2011 – website, 28.6.2011
Law of Georgia No 4935 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 4963 of 24 June 2011 – website, 30.6.2011
Law of Georgia No 5120 of 13 October 2011 – website, 19.10.2011
Law of Georgia No 5118 of 13 October 2011 – website, 31.10.2011
Law of Georgia No 5202 of 8 November 2011 – website, 22.11.2011
Law of Georgia No 5372 of 6 December 2011 – website, 20.12.2011
Law of Georgia No 5452 of 9 December 2011 – website, 22.12.2011
Law of Georgia No 5582 of 20 December 2011 – website, 28.12.2011
Law of Georgia No 5556 of 20 December 2011 – website, 30.12.2011
Law of Georgia No 5942 of 27 March 2012 – website, 12.4.2012
Law of Georgia No 5976 of 30 March 2012 – website, 19.4.2012
Law of Georgia No 6015 of 10 April 2012 – website, 30.4.2012
Law of Georgia No 6211 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6176 of 15 May 2012 – website, 29.5.2012
Law of Georgia No 6300 of 25 May 2012 – website, 8.6.2012
Law of Georgia No 6395 of 5 June 2012 – website, 19.6.2012
Law of Georgia No 6446 of 12 June 2012 – website, 25.6.2012
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Law of Georgia No 6547 of 22 June 2012 – website, 4.7.2012
Law of Georgia No 118 of 20 December 2012 – website, 29.12.2012
Law of Georgia No 189 of 28 December 2012 – website, 29.12.2012
Law of Georgia No 784 of 28 June 2013 – website, 28.6.2013
Law of Georgia No 1886 of 26 December 2013 – website, 30.12.2013
Law of Georgia No 2368 of 2 May 2014 – website, 16.5.2014
Law of Georgia No 2540 of 26 July 2014 – website, 6.8.2014
Law of Georgia No 2950 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 2952 of 12 December 2014 – website, 23.12.2014
Law of Georgia No 2946 of 12 December 2014 – website, 24.12.2014
Law of Georgia No 3015 of 26 December 2014 – website, 30.12.2014
Law of Georgia No 3407 of 20 March 2015 – website, 26.3.2015
Law of Georgia No 3581 of 1May 2015 – website, 15.5.2015
Law of Georgia No 4092 of 22 July 2015 – website, 31.7.2015
Law of Georgia No 4680 of 18 December 2015 – website, 29.12.2015
Law of Georgia No 4842 of 4 March 2016 – website, 9.13.2016
Law of Georgia No 5092 of 13 May 2016 – website, 1.6.2016
Law of Georgia No 5406 of 8 June 2016 – website, 17.6.2016
Law of Georgia No 5445 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 5491 of 22 June 2016 – website, 29.6.2016
Law of Georgia No 97 of 16 December 2016 – website, 23.12.2016
Law of Georgia No 196 of 22 December 2016 – website, 29.12.2016
Law of Georgia No 850 of 17 May 2017 – website, 2.6.2017
Law of Georgia No 1182 of 30 June 2017 – website, 13.7.2017
Law of Georgia No 1935 of 23 December 2017 – website, 29.12.2017
Law of Georgia No 2391 of 30 May 2018 – website, 12.6.2018
Law of Georgia No 3109 of 5 July 2018 – website, 11.7.2018
Law of Georgia No 3263 of 21 July 2018 – website, 1.8.2018
Law of Georgia No 4225 of 27 December 2018 – website, 31.12.2018
Law of Georgia No 4616 of 29 May 2019 – website, 30.5.2019
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Law of Georgia No 4906 of 28 June 2019 – website, 4.7.2019
Law of Georgia No 5626 of 19 December 2019 – website, 26.12.2019
Law of Georgia No 5651 of 20 December 2019 – website, 27.12.2019
Law of Georgia No 3349 of 22 May 2020 – website, 25.5.2020
Law of Georgia No 6817 of 14 July 2020 – website, 22.7.2020
Law of Georgia No 83 of 5 January 2021 – website, 6.1.2021
Law of Georgia No 1082 of 14 December 2021 – website, 17.12.2021
Law of Georgia No 1165 of 17 December 2021 – website, 28.12.2021
Law of Georgia No 1191 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 1205 of 22 December 2021 – website, 28.12.2021
Law of Georgia No 1706 of 23 June 2022 – website, 30.6.2022
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
Law of Georgia No 2590 of 9 February 2023 – website, 24.2.2023
Law of Georgia No 2983 of 18 May 2023 – website, 29.5.2023
Law of Georgia No 3350 of 28 June 2023 – website, 19.7.2023
Law of Georgia No 3958 of 15 December 2023 – website, 25.12.2023
Law of Georgia No 4014 of 15 December 2023 – website, 27.12.2023
Law of Georgia No 4022 of 15 December 2023 – website, 28.12.2023
Law of Georgia No 4197 of 29 May 2024 – website, 4.6.2024
Law of Georgia No 4364 of 27 June 2024 – website, 11.7.2024
Law of Georgia No 719 of 24 June 2025 – website, 27.6.2025
Law of Georgia No 1061 of 12 November 2025 – website, 14.11.2025
Article 3091 – Legal regulation during transition period in relation to persons declared as legally incompetent by court before 1
April 2015
1. Tax liabilities of a person declared as legally incompetent by court before 1 April 2015 shall be paid by his/her custodian at the
expense of the property of the legally incompetent person, until the individual examination of this legally incompetent person is
conducted.
2. Tax arrears of a person declared as legally incompetent by court before 1 April 2015 shall be regarded as bad debt and shall be
written off if his/her property is insufficient to cover the tax arrears, until the individual examination of this legally incompetent
person is conducted.
3. The written-off tax arrears shall be restored the day the decision is made following the individual examination of a person
declared as legally incompetent by court before 1 April 2015, unless otherwise determined under the court decision.
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6. Tax arrears of a person declared as legally incompetent by court before 1 April 2015 shall be the tax arrears as of the date when
he/she was declared as legally incompetent.
Law of Georgia No 3349 of 20 March 2015 – website, 31.3.2015
Article 310 – Final provisions
1. This Code shall become effective from 1 January 2011.
2. The following shall be declared invalid upon the entry of this Code into force:
a) the Tax Code of Georgia (Legislative Herald of Georgia, No 41, 30.12.2004, Art. 200) for the tax periods starting from 1 January
2011;
b) the Customs Code of Georgia (Legislative Herald of Georgia, No 39, 9.8.2006, Art. 280) for the tax periods starting from 1
January 2011.
3. The procedural provisions of this Code shall also apply, from 1 January 2011, to the tax periods that end before 1 January 2011.
4. Articles 173(y) and 199(r) of this Code shall be suspended until 1 January 2028.
Law of Georgia No 7204 of 30 September 2020 – website, 5.10.2020
Law of Georgia No 1165 of 17 December 2021 – website, 28.12.2021
Law of Georgia No 2439 of 16 December 2022 – website, 27.12.2022
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President of Georgia M. Saakashvili
Tbilisi
17 September 2010
No 3591–IIს
http://www.matsne.gov.ge 20000000005001016012
Legislative Herald of Georgia (Matsne)
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View the official document on Matsne CryptoLicense.ge Legal & Regulatory Team Checked: 23 August 2026 Official source: Matsne